&EPA
Office of Solid Waste and Emergency Response
              EPA 542-R-12-001
   United States
   Environmental Protection
   Agency
       Brownfields Road Map to Understanding
      Options for Site Investigation and Cleanup

                       Fifth Edition
                         Investigate the Site
                   Assess the Site
         Learn the Basics
            www.brownfieldstsc.org/roadmap

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Brownfields Road Map                                                               Acknowledgments and Notice


                            ACKNOWLEDGMENTS

                            The U.S. Environmental Protection Agency (EPA) acknowledges and thanks the
                            following individuals who contributed to the review of this document:
                                Hugo Martmez Cazon, Vermont Department of Environmental Conservation
                                Ignacio Dayrit, Center for Creative Land Recycling
                                Evan Reeves, Center for Creative Land Recycling
                                Lenny Siegel, Center for Public and Environmental Oversight
                                Elizabeth Spinelli, Hudson County Economic Development Corporation, New Jersey
                                Laura Watchman, National Association of Local Government Environmental Professionals
                                Amy Versavich, Association of State and Territorial Solid Waste Management Officials

                                U.S. EPA Staff
                                Craig Boehr               Melissa Friedland          Bob Myers
                                Janet Brooks              DebGoldblum            Laurie O'Connor
                                Ann Carroll                Sara Hartwell              Deborah Orr
                                Philip Clappin              Robin Hughes             Patricia Overmeyer
                                Deana Crumbling          Deborah Johnston         Carlos Pachon
                                Cecilia De Robertis         Diane Kelley              Karen Peycke
                                Steve Dyment             Jen Lewis                Dan Schramm
                                Steve Ells                 Chip Love                Janice Sims
                                RickEhrhart               James Miles               Paul Torcoletti
                                Jonathan Essoka           Susan Morales
                                Linda Fiedler              QueenieMungin-Davis
                            NOTICE

                            This document was funded by the EPA's Office of Solid Waste and Emergency
                            Response (OSWER) under EPA Contract EP-W-07-078. The document was subjected to
                            the Agency's administrative and expert review and was approved for publication as an
                            EPA document. The information in this document is not intended to revise or update
                            EPA policy or guidance on how to investigate or remediate brownfields or other land
                            revitalization sites. Mention of trade names or commercial products does  not
                            constitute an endorsement or recommendation for use.

                            This document can be downloaded from the EPA's Brownfields and Land
                            Revitalization Technology Support Center at www.brownfieldstsc.org/roadmap.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Contents                                                                               Brownfields Road Map

CONTENTS

Introduction	1
Follow the Brownfields Road Map	5
Brownfields Road Map Graphic	7
Learn the Basics	9
Assess the Site	17
Investigate the Site	23
Assess and Select Cleanup Options	31
Design and Implement the Cleanup	37

Spotlights
1      Redevelopment Initiatives: Connecting Cleanup and Reuse	15
2      Supporting Tribal Revitalization	16
3      All Appropriate Inquiries	18
4      Project Life Cycle Conceptual Site Model	22
5      Data Quality: The Key to Making Robust Site Decisions	25
6      High-Resolution Site Characterization and In Situ Technologies Promote
       Effective Cleanups	29
7      Vapor Intrusion	30
8      Challenging Cleanups	35
9      Understanding the Role of Institutional Controls at Brownfields Sites	36
10     Greener Cleanups	40

Online Appendices
A      Guide to Contaminants and Technologies
B      Brownfields and Technical Support Contacts
C      Acronyms and Glossary of Key Terms
                                      Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                                                  Introduction
  Introductio
  for site investigation and cleanup
                                   The Brownfields Road Map
The fifth edition features these
updates:
• Details to assist stakeholders
  with planning their
  brownfields project
• Revised "road map" graphic
• General planning assistance
  for each phase of site
  investigation and cleanup
• "Spotlights" on 10 current
  issues and best
  management practices
  (BMPs)
• Online, searchable access to
  more than 300 technical
  resources and tools
• Online guide to
  contaminants and
  technologies typically
  associated with brownfields
  sites
• Expanded glossary of key
  terms and concepts
The Brownfields Road Map to Understanding Options for Site Investigation and Cleanup,
Fifth Edition, provides a general outline of the steps in the investigation and cleanup of
brownfields sites and introduces brownfields stakeholders to the range of
technologies and resources available to them. The Road Map provides valuable
information for stakeholders typically involved in or affected by redevelopment of
brownfields sites, whether through public projects, private development or public-
private partnerships.

The first edition of the Road Map, published in 1997, provided a broad overview of the
EPA's Brownfields Program and an outline of the steps involved in the cleanup of a
brownfields site. Designed primarily for stakeholders who were unfamiliar with the
elements of cleaning up a brownfields site, the Road Map built awareness of the
advantages offered by innovative technologies. As the EPA's Brownfields Program
matured, the second (1999) and third (2001) editions were published to update
information and resources associated with the program and innovative technologies.
The fourth edition, published in 2005, provided additional resources and
supplemental information about emerging best practices, processes and initiatives
that influence the consideration and use of innovative technologies.

This edition incorporates a new approach to the Road Map through a streamlined
publication and a companion website of technical resources and tools. Stakeholders
can use the printed publication to learn about the general phases of the site
investigation and cleanup process and  gain an understanding of the considerations
associated with typical brownfields sites. The Road Map website complements the
publication by providing direct access to technical resources and tools that provide
details about technology applications, methods and other site-specific concerns.
                                       View the full contents of the Brownfields Road Map online at
                                       www.brownfieldstsc.org/roadmap.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Introduction                                                                            Brownfields Road Map

This edition of the Road Map will help:
   •   New and less experienced stakeholders. The Road Map will help these users
       learn about the EPA's Brownfields Program by introducing general concepts
       and methods for site investigation and cleanup.
   •   Decision-makers who are familiar with the Brownfields Program but are also
       interested in obtaining more detailed information. The Road Map provides
       these users  with up-to-date information about the applicability of
       technologies and access to the latest resources that can assist them in making
       technology decisions. In addition, BMPs that have emerged in recent years are
       highlighted.
   •   Community members. The Road Map helps to encourage community
       members to participate in the decision-making process by providing
       information about the general site cleanup process, as well as guidelines and
       mechanisms to promote community involvement.
   •   Stakeholders who hire or oversee site cleanup professionals. The Road Map
       includes information to help stakeholders coordinate with many different
       cleanup practitioners, such as environmental professionals, cleanup
       contractors, technology vendors or staff of analytical laboratories. The Road
       Map provides these stakeholders with a detailed understanding of each phase
       in a typical brownfields site cleanup and presents information about the roles
       that environmental practitioners play in the process.
   •   Regulators. The Road Map will increase the understanding by regulatory
       personnel of site characterization and cleanup technologies and approaches.
       The Road Map also serves as a resource that regulators can use to provide site
       owners, service providers and other stakeholders with useful information
       about the Brownfields Program.
   •   Other potential brownfields stakeholders. The Road Map helps other
       stakeholders, such as financial institutions and insurance agencies, by
       providing information for their use in assessing and minimizing risks
       associated with brownfields redevelopment.

Disclaimer

The Road Map is not an official  guidance document. Rather, it draws on the EPA's
experiences with brownfields sites, as well as Superfund sites, corrective action sites
under the Resource Conservation and Recovery Act (RCRA), and underground storage
tank (UST) sites. Specific conditions—such as the nature and extent of contamination,
the proposed reuses of the property, the financial resources available, and the level of

2                                     Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                        Introduction
                           support from neighboring communities—vary from site to site. Readers of the Road
                           Map are encouraged to explore opportunities to use the BMPs described in the
                           following pages in accordance with applicable regulatory program requirements.

                           This document provides general information and guidance regarding facilitating reuse
                           of properties. It does not address all information, factors or considerations that may be
                           relevant. This document is not legally binding. The word "should" and other similar
                           terms used in this document are intended as general recommendations or
                           suggestions that might be generally applicable or appropriate and should not be
                           taken as providing legal, technical, financial or other advice regarding a specific
                           situation or set of circumstances. This document may be revised at any time without
                           public notice. Any references to private entities, products or services are strictly for
                           informational purposes and do not constitute an endorsement of that entity, product
                           or service.

                           This document describes and summarizes statutory provisions, regulatory
                           requirements and policies. The document is not a substitute for these provisions,
                           regulations or policies, nor is it a regulation itself. In the event of a conflict between
                           the discussion in this document and any statute, regulation or policy, this document
                           would not be controlling and cannot be relied on to contradict or argue against any
                           EPA position taken administratively or in court. It does not impose legally binding
                           requirements on the EPA or the regulated community and might not apply to a
                           particular situation based on the specific circumstances. This document does not
                           modify or supersede any existing EPA guidance document or affect the Agency's
                           enforcement discretion in any way.
  How to Submit Comments

  The EPA invites comments from members of the
  brownfields community to help ensure that any future
  versions of the Road Map meet their needs. Please
  submit comments to:
     Carlos Pachon
     U.S. Environmental Protection Agency
     Office of Superfund Remediation and Technology
     Innovation
     pachon.carlostaepa.qov
     (703) 603-9904
How to Obtain Additional Copies

A printed or hard copy version of this document can be
obtained from the following source:
    National Service Center for Environmental
    Publications
    U.S. Environmental Protection Agency
    P.O. Box 42419
    Cincinnati, OH 45242-0419
    (800) 490-9198 or (513) 489-8190
    Fax:  (513)489-8695
When you order the Road Map, please refer to
document number EPA 542-R-12-001.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Introduction
Brownfields Road Map
About the EPA's Brownfields Program

Brownfields sites are defined as "real property, the expansion, redevelopment
or reuse of which may be complicated by the presence or potential presence
of a hazardous substance, pollutant or contaminant" (Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as
amended, §101 (39)). The cleanup of brownfields sites improves and protects
the environment and may result in many benefits for the local community.

The EPA established its Brownfields Economic Revitalization Initiative in 1995
to empower states, communities and other stakeholders in  economic
revitalization to work together to accomplish the redevelopment of
brownfields sites. With enactment of the Small Business Liability Relief and
Brownfields Revitalization Act in 2002, EPA assistance was expanded to
provide greater support for brownfields cleanup and reuse. Many states and
local jurisdictions also help communities adapt environmental cleanup
programs to the special needs of brownfields sites.
Summary of Brownfields
Program Accomplishments
as of January 201 2
Thousands of properties have been
assessed and hundreds of cleanups
have been completed with the
support of grants from the EPA's
Brownfields Program.
Measure
Properties Assessed
Cleanups Completed
Acres Made Ready
for Reuse
Cumulative
Results
18,204
702
33,444
Source: www.epa.aov/brownfields/
overview/bf-monthlv-report.html
                      Small Business Liability Relief and Brownfields Revitalization Act
 Since 1995, the EPA's Brownfields Program has changed the way contaminated property is perceived, addressed
 and managed. Enactment of the Small Business Liability Relief and Brownfields Revitalization Act (Public Law 107-
 118; H.R. 2869) in January 2002 expanded the EPA's assistance by providing tools that the public and private sectors
 could use to promote sustainable brownfields cleanup and reuse.
 The law modified the EPA's existing brownfields grants and technical assistance program by:
  •  Increasing the funding authority up to $200 million per year
  •  Providing grants for assessments, revolving loan funds, direct cleanups and job training
  •  Expanding the entities, properties and activities eligible for brownfields grants, including sites such as mine-
     scarred lands
  •  Expanding applicability to sites with petroleum contamination such as abandoned gasoline stations
  •  Providing authority for brownfields training, research and technical assistance
  •  Allowing local government entities up to 10 percent of the grant funds to be used to monitor the health of
     exposed populations and enforce any institutional controls
 The law changed and clarified Superfund liability:
  •  Provided liability protection for certain small-volume waste contributors and contributors of municipal solid
     waste
  •  Clarified Superfund liability for prospective purchasers, innocent landowners and contiguous property owners
 The law created a strong, balanced relationship between the federal government and state and tribal programs:
  •  Authorized up to $50 million per year for building and enhancing state and tribal response programs and
     expanded the activities eligible for funding
  •  Provided protection from Superfund liability at sites cleaned up under a state program
  •  Preserved the federal safety net by detailing the circumstances in which the EPA can revisit a cleanup
  •  Clarified the state role in  adding sites to the Superfund National Priorities List (NPL)
 Additional information on the Brownfields Law is available atwww.epa.gov/brownfields/laws/.
                                       Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                                         Follow the Brownfields Road Map
       Assess
       the Site
Investigate
 the Site
  Assess and        Design and
Select Cleanup       Implement
   Options        the Cleanup
  General phases of the site investigation and cleanup process
 Understanding the typical
 progression of the site
 investigation and cleanup
 process ensures that the
 proper groundwork is laid for
 future phases.

 Site investigation and cleanup
 typically do not occur in the
 linear sequence outlined in
 the Road Map. At many sites,
 several activities may be
 undertaken concurrently,
 while others recur throughout
 the process. Similarly, many
 technologies that are used to
 characterize sites during the
 investigation phase may also
 be used during the cleanup
 phase.
       The fifth edition of the Road Map is composed of a publication and a companion
       website. The publication presents the general phases involved in the investigation and
       cleanup of a brownfields site and introduces the reader to a range of considerations
       and activities. The website connects readers to the content of the publication online
       and provides direct access to many technical  resources and tools.

       Overview of the Road Map Publication

       The publication follows the process illustrated in the Brownfields Road Map graphic
       (see page 7). The first section, Learn the Basics, discusses important factors that set the
       stage for the investigation and cleanup of brownfields sites. The reader is introduced
       to concepts, strategies and methods that can be applied to efficiently and effectively
       prepare sites for reuse. Regulatory guidelines for the process also are introduced, and
       technologies are discussed within the overall framework of selecting site
       characterization and cleanup technologies. The remaining sections correspond to the
       general phases of site characterization and cleanup, from site assessment through
       implementation of cleanup remedies.

       Spotlights - The Road Map "spotlights" focus the reader's attention on key issues,
       processes and initiatives. They provide a quick look at topics relevant to brownfields
       projects and identify how readers can obtain  additional information. Technical
       resources and tools for each spotlight are available from the companion website.

       Online Appendices - Three appendices are provided at the Road Map Website.

          Appendix A, Guide to Contaminants and Technologies, is an online guide to
          contaminants found at more than 30 types of brownfields sites and the range of
          technologies that may be appropriate for their characterization and cleanup.
          Appendix B, Brownfields and Technical Support Contacts, provides information about
          state, tribal and EPA regional and technical points of contact.
          Appendix C, Acronyms and Glossary of Key Terms, defines acronyms and specialized
          terms used in discussing and describing brownfields cleanup efforts.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Follow the Brownfields Road Map
                                                                                     Brownfields Road Map
Features of the Road Map Website
www.brownfieldstsc.org/roadmap

The companion website provides easy access to resources and
tools. The website features:

    •  Technology resources organized by the general phases
       of the investigation and cleanup of brownfields sites
    •  Tools to help stakeholders find resources and
       publications with information that relates to their
       brownfields sites
    •  An interactive guide to contaminants and technologies

    •  A closer look at each of the spotlight topics, including
       links to related resources

    •  A list of acronyms and detailed glossary of terms
        Quick access to EPA, state and tribal brownfields and
        technical support contacts
       '
                                                         Features
                                                         Guide to Contat
                                                         Technologies
                                                         Learn ibout toil ami rants typical/ found
                                                                mts and
                                                                       Introduction
                                                                       ne srownfieKs Road *
                                                         ickable Road Map
                                                                               S i: Msi|--rd 10 Wtp rxsn-te

                                                                               effectively wit!- tKr.-.ia'.
                                  Follow the Road Map
                                  Learn how the flaad Map publication suS tliis web

                                  deanup ortessi, as ifcjstratefl in ins roaa map iHu

                                  Learn the Basics



                                  brownfieWs project.

                                                       IT* "s;»ttiShts" previse 3
                                                       quick, too* at t«sics rete-m
Guide to Contaminants
   and Technologies
 Spotlights with Links
to Additional Resources
                                                  All Appropriate Inquiries Rule:
 Presents detailed information about
 contaminants found at brownfields
 sites and technologies used to
 investigate and treat them.
                                Provides access to the spotlights
                                presented in this publication and
                                links to relevant resources.
                                Resources can be previewed or
                                downloaded from the companion
                                website.
                                                                       Investigate the Site
                                                                       information aaectet: taring tr* site investigator. p*as

                                                                       an: reuse alternatives.

                                                                       Assess and Select Cleanup Options

                                                                       to i
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I  The Brownfields Road Map illustrates
I  the general steps involved in the
I  investigation and cleanup of a
  brownfields site.

  Actual steps may vary depending on
  site conditions and applicable state
  and federal regulations. Stakeholders
  should consult with appropriate
  regulatory agencies throughout the
  process and enlist qualified technical
  and legal services.

  View an interactive, online map at
  www.brownfieldstsc.org/roadmap
  that contains links to information
  about the general phases and
  spotlight topics.
 Brownfields  Road  Ma
  Learn the Basics

  Before you begin down the path
  outlined in the road map, it is
  important to get prepared.
  Preparation typically consists of
  the following activities:


  O  Setting reuse goals
      and planning
      Understanding regulations,
      regulatory guidelines and
      liability concerns

      Engaging the community

      Identifying funding

      Seeking professional
      support
                                                                                                                                            Site
                                                                                                            *eu&e
                             Was the contamination
                              adequately removed,
                             contained or controlled?
         Discovery of additional
      contamination during cleanup
       may require returning to the
        Investigate the Site phase.
 Consult appropriate
regulatory authorities
           Begin
             Here
                                            the project still oc
                                        given the cleanup options?
                                                                                    Is there a practical
                                                                                    redevelopment or
                                                                                    reuse alternative?
                                                                                                           Consult appropriate
                                                                                                          regulatory authorities
    Proceed cautiously if your
   site is likely to require costly
   or complex cleanup. See the
     spotlight on Challenging
          Cleanups.
Can risks be managed adequately
to the satisfaction of stakeholders
  in light of the proposed reuse?
                                                  Can redevelopment and reuse
                                                    occur without cleanup?
                                                                                                       Is there an
                                                                                                    immediate threat
                                                                                                    to local residents?
                                                               Consult appropriate
                                                              regulatory authorities
                                                          Was contamination found?
   View the spotlight on
Redevelopment Initiatives to
learn more about how EPA is
helping communities prepare
    properties for reuse.
                                                                                             General phases of site
                                                                                             characterization and cleanup
                                                                                             Questions potentially
                                                                                             affecting the course of the
                                                                                             site characterization and
                                                                                             cleanup process
   Additional investigation    /\
  may be required based on 
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Brownfields Road Map
                                                                    Learn the Basics
    ear
asics
   O Setting reuse goals and planning
   • Understanding regulations, regulatory guidelines
      and liability concerns
   O Engaging the community
   """> Identifying funding
      Seeking professional support
                                      Redevelopment
                                      Initiatives
 Supporting Tribal
i Revitalization
                                Begin Your Trip Here
 Begin here to learn about
 factors and considerations that
 affect cleanup at a brownfields
 site. These "basics" are integral
 to the cleanup process and the
 overall success of the
 brownfields project.
 General concepts and terms
 related to the investigation and
 cleanup of brownfields sites are
 introduced here and reinforced
 throughout the publication.

 Brownfields Stakeholders
 A stakeholder is typically
 considered an individual who is
 part of the decision-making
 process or can influence
 decisions. Stakeholders for
 brownfields projects may
 include:
 - Federal, state and local
  agencies
 - Local elected officials
 - Local and regional
  community development
  agencies
 - Developers
 - Community members
 - Tribes
 - Property owners
 - Academia
 - Potentially responsible
  parties (PRP)
 - Private industry
 - Non-profit organizations
   Brownfields projects may be initiated for a number of reasons. A landowner may want
   to sell a property to a prospective purchaser for development. A municipality may
   want to clean up a parcel or area that has become a public hazard or eyesore, create
   space for business development or build a park. A local comprehensive plan may call
   for infill development of a certain type in a brownfields area. In these cases, the
   brownfields process will be tailored to the specific end use envisioned for the
   property.

   Preparing a brownfields site for reuse involves more than the investigation and
   cleanup of a property. The interests of many stakeholders must  be integrated into the
   overall redevelopment process. Cleanup strategies vary from site to site, depending on
   factors such as intended end use, available funding, liability considerations, regulatory
   requirements, the type and extent of contamination present, and the technologies
   available for cleanup. At some sites, cleanup will be completed before the properties
   are transferred to new owners. At other sites, cleanup may take  place simultaneously
   with construction and redevelopment.

   Regardless of when and how cleanups are accomplished, a key challenge to
   brownfields projects is to clean  up sites in accordance with reuse goals and
   appropriate laws and regulations. It is essential that stakeholders become familiar with
   factors that play a significant role in the success of a brownfields project, such as
   understanding applicable regulations, engaging members of the community,
   identifying funding and obtaining professional support.

   Setting Reuse Goals and Planning

   From the outset, it is important to consider potential reuse goals. A reuse plan based
   on those goals (or lack thereof) will govern most brownfields projects, from identifying
   site investigation and cleanup standards, to obtaining competitive financing
   potentially critical to the ultimate affordability or profitability of the project. Keep in
   mind, however, that new information about contamination or cleanup needs may
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Learn the Basics
                                                 Brownfields Road Map
require that reuse plans be altered. Be prepared to develop a flexible
project plan that will evolve as information is collected, community
input is received and decisions are made about the cleanup approach.

Establishing reuse goals for a brownfields project also helps the project
team to define the decisions to be made throughout the project, which
is fundamental to selecting appropriate technologies for site
investigation and cleanup. When carefully selected, technologies enable
those responsible for the brownfields project to collect the data
necessary to support those decisions and accomplish the established
goals.

If reuse goals are not known at the beginning of the project, the
stakeholders should at a minimum make every attempt to identify the
general type of desired development, whether industrial, commercial,
residential or mixed-use. Absent that information, the most conservative
assumptions should be applied at every stage of the  brownfields
project, a circumstance that could significantly increase the time and expense of the
project, potentially up to the point of making the project infeasible.

Understanding Regulations, Regulatory Guidelines and Liability Concerns

                              State and Tribal Response Programs
                              Many states have established formal
                              agreements with the EPA to facilitate
                              assessment, cleanup and redevelopment
                              of brownfields sites. The agreements,
                              referred to as Voluntary Cleanup
                              Programs (VCP), create a framework for
                              states and the EPA to coordinate the
                              oversight of the cleanup process. VCPs
                              provide technical assistance, liability
                              assurances and funding support to site
                              owners and developers. Learn more at
                              www.epa.gov/compliance/cleanup/
                              revitalization/state.html.
                              The EPA provides access to information
                              about tribal brownfields programs at
                              www.epa.gov/brownfields/state tribal/
                              tribe  proas.htm.
The redevelopment of brownfields sites may be subject to a variety of
federal, state and local laws, regulations, policies and guidelines with
respect to the characterization and cleanup of the site. These sites also
may be governed by the standard practices of other government,
nongovernment and private institutions.

The applicable laws, regulations, policies and guidelines will vary by site,
depending on the regulatory authorities that have oversight authority
for cleanup. Therefore, it is important to research this information at the
outset and to work closely with the regulatory authorities throughout
the cleanup process. For example, state or local regulatory authorities
may oversee the cleanup of brownfields sites. These agencies should be
consulted to determine what, if any, site-specific requirements, reviews,
approvals or permits are applicable.
                              Example of Regulatory Requirement
                              If the proposed end use calls for
                              construction of a light industrial facility, it
                              may be appropriate, depending on state
                              and local regulatory requirements, to
                              compare the relevant cleanup standards
                              for industrial as well as commercial or
                              residential reuse standards. If the more
                              stringent standard required for
                              commercial or residential reuse is used,
                              additional cleanup and costs may be
                              required initially, but doing so provides
                              greater flexibility and avoids future
                              delay(s) if the proposed reuse is likely to
                              change.
At the EPA, the Office of Site Remediation Enforcement (OSRE) supports
cleanup and revitalization by issuing enforcement discretion guidance
documents, model enforcement documents, responses to frequently
asked questions, fact sheets and other documents. OSRE works with the
EPA regional offices to provide guidance on relevant enforcement tools to potential
                             The standards required will affect every
                             aspect of the project, from its overall cost
                             (which is generally greater as the
                             standards become more conservative) to
                             the selection of options for site
                             investigation and cleanup.
10
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map                                                                          Learn the Basics
  „  _        ,  „    ,                          developers and owners of contaminated land. These
  Key Resource for Regulatory
  and Liability Concerns                          documents, along with current Superfund enforcement and
  The Revitalization Handbook, updated and reissued    brownfields PolicV and 9uidance documents, are available on
  in 2011 by EPA's OSRE, is designed for stakeholders   the EPA's website at http://cfpub.epa.gov/compliance/
  involved in the assessment, cleanup and            resources/policies/cleanup/superfund/. The EPA also can be a
  revitalization of contaminated sites. The handbook     .   , .           ,   .     „  . ,  .  .  ,  .  ,   ,       ...
            ,  ,   .......        ••      jmA      valuable resource for brownfields stakeholders by providing
  summarizes federal statutory provisions and EPA                                                 '^       a
  policy and guidance documents useful for
  managing liability risks associated with cleaning
regulatory and policy support to facilitate selection of
technologies. See Appendix B, Brownfields and Technical
  up sites, and describes tools that stakeholders can            Con      Qn (he Brownfie,ds Road M  websjte for
  use to address liability concerns. The handbook,
  including recent updates, is available at             contact information.
  www.e pa .q o v/co m p I ia n ce/reso u rces/
  publications/cleanup/brownfields/handbook/.
Many of the standard practices are designed to help
brownfields redevelopment projects obtain financing from
                            public programs and private banks and institutions. Guidance and standards are
                            issued by government and nongovernment organizations, such as ASTM International
                            (formerly the American Society for Testing and Materials), the Federal Deposit
                            Insurance Corporation (FDIC), state and local economic development authorities and
                            private lenders.

                            Regulatory considerations at relevant phases of investigation and cleanup are
                            identified in the following sections. Stakeholders are encouraged to regularly consult
                            with appropriate regulatory agencies to ensure that requirements are properly
                            addressed throughout the project.

                            Engaging the Community

                            Encouraging active participation by members of the community who are most likely
                            to be affected by site cleanup and reuse plans contributes to the success of the
                            project. Engage the community to raise awareness, identify community concerns and
                                                build support for cleanup efforts that will  lead to
  Key Resource for Community Engagement
                                                redevelopment and revitalization  of their community. To
  EPA's Brownfields Program is designed to promote    maxjmjze chances for ju          e    for how the
  the active participation of communities in each
  phase of the cleanup process so that revitalized      community stakeholders will be identified and encouraged to
  land offers the greatest local benefit.               participate for the duration of the brownfields project, from the
  A detailed overview of opportunities to engage      investigation phases throughout cleanup.
  the community in a brownfields project, including
  the identification of public actions at each step, is     it js important that brownfields decision-makers encourage
  depicted graphically at www.epa.gov/oswer/              .      f       .       ,  .       ..    ..    ,
    r     M   r   / „	,. ,  , ,	;	        acceptance of reuse plans and cleanup alternatives by
  engagementimtiative/brownfields.html.
                                                involving members of the community through multiple
                            outreach methods such as public meetings, newsletters, publications, websites and
                            social networks. For an individual site, the community should be informed about how


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Learn the Basics
                                                Brownfields Road Map
the use of a proposed technology might affect redevelopment plans
or the adjacent neighborhood. Consider how the people living in or
near the site might be affected by cleanup activities and the intended
reuse of the property; plan early and appropriately for how cleanup
decisions and their potential impact will be shared with the
community.

The EPA assists brownfields communities by directing its members to
appropriate resources and providing opportunities to network and
participate in sharing information. A number of websites, databases,
newsletters and reports provide opportunities for brownfields
stakeholders to network with other stakeholders to identify
information about cleanup and technology options. Details about the EPA's
community engagement efforts by the Office of Solid Waste and Emergency Response
(OSWER) are available on the Community Engagement Initiative website at
www.epa.qov/oswer/enqagementinitiative/. Helpful tools and data focused on
community engagement at UST sites are provided on the EPA's Office of Underground
Storage Tanks (OUST) community engagement website at
www.epa.qov/oust/communityenqaqement/.

Identifying Funding
                           Technical Assistance for Communities
                           The EPA's Technical Assistance to
                           Brownfields Communities (TAB) program is
                           a valuable community resource. Organized
                           to provide geographically based assistance,
                           the TAB program increases understanding
                           of technical issues associated with
                           brownfields sites and helps community
                           members learn how to participate in
                           cleanup and revitalization activities.
                           Details, including how to request technical
                           assistance, are provided online at
                           www.epa.gov/brownfields/tools/.
One of the most important factors to consider at the beginning of a
brownfields project is funding. Simply put, the project cannot be
initiated or undertaken until funding sources are identified and funds
are secured. The success of a brownfields project is determined by the
ability of the stakeholders to establish a funding package that covers
the project costs from planning and assessment through cleanup and
long-term monitoring. Most brownfields projects leverage funding
from a variety of sources. Be mindful that securing funding can be a
lengthy process.

The range of potential sources and the means of securing  funds can
appear overwhelming, but fortunately, many helpful resources and
tools are available to guide stakeholders in exploring funding options.
Funding for the investigation and cleanup of brownfields sites is available from
federal, state and public and private sources. Programs available at the federal level,
such as the EPA, typically involve awarding grants and providing technical assistance
to communities and stakeholders. Other federal programs, such as the U.S.
Department of Housing and Urban Development, the U.S. Department of Agriculture,
the U.S. Department of Transportation and the U.S. Department of Commerce, also
                           EPA Brownfields Grants
                           The EPA offers funding for brownfields
                           assessment, cleanup, revolving loan fund
                           and environmental workforce development
                           and job training grants. Learn more about
                           the EPA's brownfields grants at
                           www.epa.gov/brownfields/grant info.
                           Summaries of the types of grants are
                           provided, including fact sheets, guidelines,
                           resources, eligibility requirements, funding
                           levels and tips for applying. Specific
                           instructions and deadlines for applying for
                           the EPA's brownfields grants are provided
                           atwww.epa.gov/brownfields/applicat.htm.
12
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Brownfields Road Map                                                                            Learn the Basics
  Key Resource for State Programs
                                                     provide funding and technical assistance for brownfields
    ....        .            ,,           ,  , ,        projects. State programs are a valuable option as well, as
  Published in 2011 by the EPA's Office of Brownfields       K  J          K   y                   K
  and Land Revitalization (OBLR), the State Brownfields       states are increasingly offering flexible tools, financial
  and Voluntary Response Programs: An Update from the     assistance, tax incentives and other redevelopment
  States provides helpful information about programs       support tQ promote dea    and reuse of brownfie|ds sites.
  and tools available for brownfields projects through
  state programs. State-specific details are provided,
  including financial assistance tools, such as funding, tax
  incentives and environmental insurance; funding
  sources, amounts and whether the state program
  www.epa.gov/brownfields/state  tribal/pubs.htm.
                         At the beginning of the project, explore federal, state and
                         local programs to learn about the sources of funding
                         available and the process for applying for and securing
  focuses on specific types of properties; liability relief      ,         ,     ,         , ,        ,   ,  , ,
  provisions; and contact information.                    fundm9'Take advanta9e of the manV helPful resources
                                                     available on the EPA's Brownfields website
  The resource is available online at
                         (www.epa.gov/brownfields/qrant info/) to learn about the
                         EPA's grant programs, details about federal tax deductions
and to access state response programs, including points of contact and success
stories.

Seeking Professional Support

Most decision-makers for brownfields sites will require technical and legal assistance
to fully understand the complexities of investigating and cleaning up contaminated
sites. Depending on the complexity of a particular site, decision-makers may need the
assistance of environmental practitioners with expertise in geosciences, chemistry,
engineering, field sampling, redevelopment and other disciplines; cleanup
contractors; technology vendors; and  staff in analytical laboratories to perform many
of the activities required to investigate and clean up the site. The inclusion of these
professionals and other experts as members of a brownfields project team is
recommended to ensure the successful completion of the brownfields project.
           .,..„,   .    ,         Regulations applicable to brownfields projects in some states require the
  Using Certified Professionals                                              J
                                    participation of certified or licensed environmental professionals to help
  Some states require the                  ,  ,                      ,  ,                        ,
  participation of certified or licensed    9uide the site investigation and cleanup process. For example, the EPA's final
  professionals to help guide the site    rule for All Appropriate  Inquiries (AAI) requires that AAI investigations be
  investigation and cleanup process.    performed or supervised by individuals who have specific certification or
                                    licensure, education or experience levels that meet the definition of
                             "Environmental Professional" provided in the AAI final rule. A request for proposal
                             (RFP) is often used as the procurement mechanism to obtain the services of such
                             professionals (individuals or a firm). The RFP requests potential service providers to
                             submit a proposal that addresses the approach, qualifications and cost estimate for
                             the services requested. The RFP can include specifications that encourage prospective
                             bidders to think "outside the box" and consider innovative approaches. Selection
                             criteria outlined in the RFP should include the demonstrated experience of the

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Learn the Basics                                                                          Brownfields Road Map

individuals or firm in developing valid options for using streamlined strategies and
innovative technologies at brownfields sites and in successfully implementing the
selected options. Demonstrated experience can include resumes, project descriptions
and letters of recommendation.

Seeing the Bigger Picture - Related EPA Initiatives

As the EPA's Brownfields and Land Revitalization Program has matured over the years
to address new challenges and evolving stakeholder needs, new programs and
initiatives have been undertaken to better integrate efforts to clean up and reuse
brownfields sites. See Spotlight 1, Redevelopment Initiatives: Connecting Cleanup
and Reuse, and Spotlight 2, Supporting Tribal Revitalization, for a brief overview of
several programs and initiatives that are designed to help the brownfields community
integrate revitalization efforts, including principles such as sustainability, renewable
energy and smart growth. In addition to setting policy and providing guidelines, these
programs offer extensive resources to help brownfields stakeholders apply lessons
learned from the experiences of other redevelopment projects.

Find Helpful Resources

          Visit the Brownfields Road Map website for resources to learn more about
           general concepts and factors for the cleanup of brownfields sites. The
           Learn the Basics resources provide more general information than the
          technology resources identified in the following chapters.
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Brownfields Road Map
                           Learn the Basics
      Spotlight 1
          Redevelopment Initiatives:
       Connecting Cleanup and Reuse
  Listed below are highlights of several EPA prog rams and initiatives focused on helping brownfields stakeholders learn how to
  more efficiently and collaboratively prepare contaminated properties for reuse.
                           Initiative / Program
 Available Resources / Additional Details
   Land Revitalization Program - The Land Revitalization Program's mission is
   to restore land and other natural resources into sustainable community assets
   that maximize beneficial economic, ecological and social uses and ensure
   protection of human health and the environment. The Land Revitalization
   Program promotes sustainable approaches to remediation as the norm across
   all EPA contaminated land programs, recognizing cleanup and reuse as
   mutually supportive goals. The program emphasizes that the consideration of
   anticipated property reuse should bean integral part of cleanup decisions.
Resources, policies and guidance, success
stories and details about the program are
available online at www.epa.gov/
landrevitalization. Links to program-specific
information, including details about grant
and funding resources, are also provided.
   Brownfields Area-Wide Planning Pilot Program - This program supports
   community involvement in locally based efforts to plan for the assessment,
   cleanup and reuse of brownfields sites within a defined area. Through grants
   and technical assistance, the program promotes land revitalization on a larger
   scale than a single brownfields site (for example, revitalization of a
   neighborhood, block or corridor affected by a brownfields site) and promotes
   community engagement in the planning for brownfields revitalization efforts.
Details about the pilot program, including
pilot project fact sheets and information
about applying for funding, are available at
www.epa.gov/brownfields/
areawide grants.htm.
   Petroleum Brownfields Action Plan:  Promoting Revitalization and
   Sustainability - The EPA launched this program in 2008 to address the
   unique challenges associated with the cleanup and reuse of brownfields sites
   with petroleum contamination.
Visit www.epa.gov/oust/
petroleumbrownfields to access the action
plan, progress reports, success stories,
grants information and other resources.
   Smart Growth - The EPA's Smart Growth program provides tools and
   resources to help people implement sustainable development strategies that
   promote healthy, attractive and economically strong communities.
   Integrating community, environmental and the economic considerations,
   applying smart growth principles to brownfields sites can lead to the
   selection of more valuable and sustainable reuse alternatives.
To learn more about the EPA's Smart
Growth program, visit www.epa.gov/
smartgrowth/. Resources, tools, technical
assistance and examples of successful
smart growth approaches are provided.
   Re-Powering America's Land - Launched in 2008, this initiative encourages
   renewable energy development on current and formerly contaminated land
   and mine sites. Efforts focus on identifying the renewable energy potential of
   sites and providing useful resources for communities, developers, industry
   and state and local governments and others  interested in reusing these sites
   for renewable energy development.
Visit www.epa.gov/oswercpa/ for
information about funding sources,
technical assistance, fact sheets, interactive
mapping tools to identify sites with
renewable energy potential, webinars and
federal and state incentives.
   Superfund Redevelopment Initiative (SRI) - Since 1999, SRI has helped
   communities return some of the nation's worst hazardous waste sites to safe
   and productive uses. In addition to cleaning up these Superfund sites and
   making them protective of human health and the environment, the Agency is
   working with communities and other partners to consider future use
   opportunities and integrate appropriate reuse options into the cleanup
   process. The EPA is also working with communities at sites that have already
   been cleaned up to ensure long-term stewardship of site remedies and to
   promote reuse.
Webinars, success stories, tools and
resources, community support,
demonstration project fact sheets,
partnership information and complete
details about the initiative are available
online at www.epa.gov/superfund/
programs/recycle/.
         Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight ri.cfm.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Learn the Basics
                                                   Brownfields Road Map
      Spotlight 2
       Supporting Tribal Revitalization
  Federally recognized tribes in the United States develop their own
  environmental policy, establish standards and manage their
  environmental protection and natural resource management programs.
  Tribes can establish a brownfields program or a Tribal Response Program
  to address and reuse contaminated lands. The EPA provides technical
  and financial assistance to tribes for the restoration of contaminated
  tribal lands and the implementation of more effective approaches to
  attaining productive reuse of sites.

  Financial and Technical Assistance Provided by the EPA

    • State and Tribal Response Program Grants can be used to establish
      new or enhance existing environmental response programs.

    • Assessment, Revolving Loan Fund and Cleanup Grants (ARCGrants)
      fund activities for sites contaminated by petroleum, hazardous
      substances, controlled substances or mine-scarred land.

    • Job Training Grants fund opportunities for residents to take
      advantage of jobs created by the assessment and cleanup of
      brownfields sites.

    • Technical Assistance to Brownfield Communities (TAB) Grants provide
      technical or training assistance to increase community
      understanding and participation in the brownfields remediation
      process.

    • Targeted Brownfields Assessments (TBA) provide direct technical support for environmental assessment activities, which
      may be an option for sites that are not strong candidates for competitive grants.

    • Limited funding also is available through Superfund cooperative agreements for program development and site
      assessment.

  Tribal Highlights

    • The Passamaquoddy Tribe used funds from the Tribal Response Program to create an inventory of contaminated
      properties. The tribe also received assistance from the Maine Department of Environmental Protection's Brownfields
      Program to assess the Sipiyak Corner Store property, which included a vacant gas station. Discovery of contaminated soil
      resulted in the removal  of USTs, and the site is now ready for reuse.

    • The Absentee Shawnee Tribe has used funds from the EPA Brownfields Job Training grants to train more than 124
      students on topics ranging from asbestos remediation to Hazardous Waste Operations and Emergency  Response
      (HAZWOPER) health and safety training. Graduates of the training program have been employed by the Tribe's Office of
      Environmental Protection and other environmental firms and formed their own remediation company.

  For More Information

  Additional information about tribal grant funding guidance, tribal response program publications and tribal  brownfields
  programs is available online at www.epa.gov/brownfields/state tribal.
                          SHARED SUCCESS
  iBMEIlg
  ^www   Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_tr.cfm.
  Road Map
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Brownfields Road Map
                                                                  Assess the Site
The site assessment is a
crucial step in the brownfields
process because the need for
any further environmental
investigation and cleanup will
depend on whether potential
environmental concerns are
identified.
Collect and Assess Information about Your Brownfields Site

The purpose of this phase is to evaluate the potential for contamination at a particular
site by collecting and reviewing existing information. A site assessment includes a
review of site and government records, a site visit to visually inspect existing site
conditions and identify any potential releases of hazardous substances, and interviews
with people who have direct knowledge about historical uses of the site, past and
current operational practices, and any potential for related environmental concerns.
          ASTM International
              Phase IESA
 The site assessment is usually
 conducted consistent with ASTM
 International Phase I ESA practices,
 which are the generally accepted
 standard for evaluating a site for a
 potential release of hazardous
 substances or petroleum products into
 site structures, soil, groundwater,
 surface water, sediment and indoor air.
 Each instance when the available
 information suggests that a release of
 hazardous substances or petroleum
 products may have occurred is
 designated as a recognized
 environmental condition (REC).
 For more information about the ASTM
 International standard practice, visit
 www.astm.org/Standards/E1527.htm.
           A site assessment—typically beginning with a Phase I Environmental Site
           Assessment (ESA)—is essentially a compilation and review of available
           information. Efforts conducted during a site assessment to evaluate the
           history of a site and determine whether contamination is present also can
           be used to comply with the requirements of an AAI investigation.
           Conducting an AAI investigation is one element required for obtaining
           liability protection. See Spotlight 3, All Appropriate Inquiries, for details on
           the requirements for performing an AAI investigation.

           During the site assessment phase, it is important to consider the activities
           and requirements described in the subsequent chapters and determine
           how they may be affected by initial site assessment information. Because
           the information obtained in this phase will determine whether any future
           site investigation work must be done at the site, assessment activities
           should be thorough and tailored to meet site- and project-specific data
           objectives. The information collected during this initial phase of the
           brownfields project is extremely important for providing early indications
           of whether the property may need to be cleaned up to support its
           intended reuse and can provide a preliminary indication of the available
           cleanup technologies.
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Assess the Site
                                                   Brownfields Road Map
The information collected about the site is typically organized into a
project life cycle conceptual site model (CSM). The CSM is a valuable
planning tool and framework for designing site activities and facilitating
communications of the project team and with stakeholders. See
Spotlight 4, Project Life Cycle Conceptual Site Model, for details and access
to examples of CSMs.

                                 Community Benefit
                                 The CSM is useful for sharing
                                 information with community members
                                 about the environmental conditions of
                                 the site, goals for the cleanup, data to
                                 be collected and decisions to be made.
 All Appropriate Inquiries is the process of evaluating a property's history and
 environmental condition to determine whether any contamination may be
 present. AAI investigations are required to be performed for a future properly
 owner to be considered an innocent landowner, contiguous property owner, or
 bona fide prospective purchaser under the Comprehensive Environmental
 Response, Compensation and Liability Act (CERCLA), or Superfund.

 Conducting AAI Investigations
 AAI investigations must be performed within a certain time frame and manner and
 by individuals with specific qualifications to be considered compliant with the AAI
 final rule, published at 40 Code of Federal Regulations (CFR) Part 312 (effective November 1,2006). Specific requirements
 include the following:

    • An AAI investigation must be performed or updated within 1 year prior to acquisition of the property.

    • Specific activities required by the AAI final rule that must be performed or updated within 180 days before acquisition of
     the property include an onsite visual inspection, review of government records, interviews with previous and current site
     owners and searches for environmental cleanup liens.

    • AAI investigations must be performed or supervised by individuals who have specific certification or licensure, education
     or experience levels that meet the specified definition of "Environmental Professional" provided in the AAI final rule.

    • The findings of an AAI investigation must be documented in a written report. The report must include:

      1)  An  opinion as to whether the inquiry identified conditions indicative of releases or threatened releases of hazardous
         substances on, at, in or to the subject property,

      2)  An  identification of "significant" data gaps if they affect the ability of the environmental professional to identify
         conditions indicative of releases or threatened releases,

      3)  Qualifications and signature of the environmental professionals, and

      4)  An  opinion regarding additional appropriate investigation, if the environmental professional has such an opinion.

    • AAI requirements may be met using the ASTM El 527-05  Phase I Environmental Site Assessment Process or ASTM E2247-
     08  Phase I Environmental Site Assessment Process for Forestland or Rural Property.

 For More Information
 Visit the EPA's All Appropriate Inquiries website at www.epa.gov/brownfields/aai/ for fact  sheets about AAI, access to the EPA's
 published final rule on AAI (40 CFR Part 312), and other information.
        Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_aai.cfm.
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Brownfields Road Map
                                                                  Assess the Site
  Consider These Questions
 Goals and Planning
 » Has a redevelopment plan
  been prepared or a
  proposed end use
  identified?
 » Is a residential development
  planned?
 » If located in an industrial
  area, will the site remain
  industrial or be rezoned for
  commercial use?
 » If the site shows evidence of
  contamination, who and
  what will be affected?
 » Will users of the property be
  exposed directly to the site
  soil, soil vapor, sediment or
  surface water?
 » Who will conduct long-term
  monitoring and oversight,
  particularly if residual
  contamination is left in
  place?


 Oversight
 » Is the site located in an area
  targeted for
  redevelopment? If so, is the
  site being considered for
  cleanup under a federal or
  state Superfund cleanup
  initiative?
 » Will the site be entered into
  a VCP? If not, what agency
  (federal, state, local or tribal)
  is responsible for managing
  oversight of cleanup?
 » Are there other federal,
  state, local or tribal
  regulatory requirements for
  site assessment?
 » Are there other regulatory
  requirements for specific
  contaminants likely to be
  present on the site (for
  example, lead-based paint
  or asbestos)?
The needs and concerns of the community are also important considerations at this
early step. For example, it may be beneficial to develop social and economic profiles
and clearly identify what the community considers to be acceptable environmental
risks. Discussions and planning for how to identify stakeholders and keep them
engaged and actively participating throughout the entire project are important
activities to be undertaken in conjunction with site assessment.

Technologies that detect possible contamination in indoor air may be applicable at
this stage, as well as some real-time measurement technologies useful for assessing
contamination in soil, groundwater, surface water or other environmental media.
Examples of sampling and analysis technologies that may be applicable during this
phase are presented in the online Guide to Contaminants and Technologies at the
Brownfields Road Map website. However, the use of technologies is limited, since
much of the work at this phase typically involves a search of paper and electronic
records and interviews with current and previous site owners and workers.

Conduct Your Site Assessment

Typical activities that may be conducted during the site assessment phase are
indicated below. The list is intended as a general planning guide and is not a
comprehensive listing of assessment activities required under state and federal
regulations. Factors that should be considered are presented in the margin in the form
of questions. Fora better understanding of these requirements, such as the EPA's AAI
regulations, consult the references identified and work with appropriate regulatory
authorities.

    •    Establish the core technical team and take advantage of the team's expertise
        to evaluate the adequacy of existing site information and identify potential
        releases of hazardous substances or petroleum products.
        o   Identify and secure experts in geosciences, chemistry, engineering,
           regulatory and field sampling.
        o  As required, consider additional support from individuals experienced in
           risk assessment, biology, data management and quality assurance.
    •    Ensure that all brownfields stakeholders (such as regulators, community
        members, property owners and technical staff, such as chemists and
        engineers) are involved in the decision-making process.

    •    Identify future plans for reuse and redevelopment and goals of the site.
    •    Explore options for funding and technical assistance from the EPA.
        o  Consider applying for a brownfields assessment grant.
        o   Request technical  assistance from the EPA's Targeted Brownfields
          Assessment (TBA)  program.
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                                                 Brownfields Road Map
    •   Assess the site through an ASTM International Phase I ESA or its equivalent and
       conduct AAI to determine whether contamination is likely present on site. In
       general, perform a records search, visit the site and interview individuals with
       knowledge of the site. The effort includes the following activities:
       o   Search relevant environmental databases. Commercial firms can cost-
           effectively conduct database searches on a fee basis. The search will
           consist of a review of federal and state databases, including but not
           limited to: (1) the EPA's Comprehensive Environmental Response,
           Compensation and Liability Information System (CERCLIS) of potentially
           contaminated sites, (2) RCRAInfo, a national program management and
           inventory system of hazardous waste handlers, (3) the National Pollutant
           Discharge Elimination System (NPDES) of permits issued for discharges
           into surface water  and (4) state records of "emergency removal" actions
           (for example, the removal of leaking drums or the excavation of explosive
           waste).
       o   Identify past owners and the uses of the property by conducting a title
           search and reviewing tax documents, city directories, sewer maps,
           topographic maps, aerial photographs and fire, policy and health
           department documentation related to the property.
       o   Analyze city government and other historical records to identify past use
           or disposal of hazardous or other waste materials at the site.
       o   Interview property owners, occupants and others associated with the site,
           such as previous employees, residents and local planners.
       o   Perform a walking  inspection of the site and a visual evaluation of adjacent
           and other local properties.
       o   Potentially collect samples to test for the presence of various contaminants
           — for example, lead-based paint, asbestos and radon in structures.
       o   Plan additional investigations at the site and collect information as
           necessary to investigate any releases of hazardous substances identified
           during the site assessment and resolve any other uncertainties  related to
           the site.
    •   Coordinate with the project team to begin development of the project life
       cycle CSM.

    •   Review the applicability of government oversight programs:
       o   Determine whether there is a state VCP and consult with the appropriate
           federal, state, local and tribal regulatory agencies to include them in the
           decision-making process as early as possible.
       o   Select the approach (such as redevelopment programs, federal regulatory
           programs, property transfer laws or a state brownfields program) that is
           required or available to facilitate the cleanup of the site.
       o   Identify whether economic incentives, such as benefits from state
           brownfields programs or federal  brownfields tax deductions, can be
           obtained.
       o   Contact the EPA regional brownfields coordinator to identify and
           determine the availability of EPA support programs and federal financial
           incentives (see Appendix B, Brownfields and Technical Support Contacts).
                                           Consider These Questions
                                                 (continued)


                                         The Community
                                         » What are the special needs
                                           and concerns of the
                                           community?
                                         » How can meaningful
                                           community involvement be
                                           solicited?
                                         » What environmental
                                           standards should be
                                           considered to ensure that
                                           community stakeholders are
                                           satisfied with the outcome
                                           of the cleanup?


                                         Site Conditions
                                         » What is known about the
                                           site?
                                         » What records exist that
                                           indicate potential
                                           contamination and past use
                                           of the property and adjacent
                                           properties?
                                         » What information is needed
                                           to identify the types and
                                           extent or the absence of
                                           contamination?
                                         » Has a previous Phase I ESA
                                           been conducted?
                                         » Have other environmental
                                           actions occurred (such as
                                           notices of violation)?


                                         Funding
                                         » Who will pay for the site
                                           investigation and cleanup?
                                         » Are private, state, city or
                                           other federal agency funds
                                           available?
20
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Brownfields Road Map
                          Assess the Site
                               •   Decide how to encourage and incorporate community participation:
                                   o  Identify regulatory requirements for public involvement.
                                   o  Assess community interest in the project.
                                   o  Identify community-based organizations.
                                   o  Review any community plans for redevelopment.

                               •   Examine factors that may impede redevelopment and reuse.
                               •   Identify environmental or other site conditions that the community would
                                   likely find unacceptable in light of the proposed reuse.
                               •   Begin identifying potential sources for funding site investigation and cleanup
                                   activities at the site, if necessary.

                            Find Helpful Resources
                                      Visit the Brownfields Road Map website to identify and review resources
                                      and tools that provide details about technology applications, methods and
                                      other site-specific concerns.
                            Plan Your Next Step

                            The next course of action is determined by the results of the site assessment and what
                            has been learned about the site. Several possible outcomes and subsequent courses of
                            action are explained below.
                             Result of Site Assessment
                             No evidence of contamination is found
                             and there is no evidence of possible
                             contamination. Stakeholder concerns
                             have been addressed adequately.
                             Evidence of contamination is found
                             that poses a significant potential  risk to
                             human health or the environment.
Course of Action
Confirm results with appropriate
regulatory officials before proceeding
with redevelopment activities.
                             Contamination possibly exists, as
                             indicated by the presence of RECs.
                             Contamination definitely exists, but no
                             site investigation has been conducted.
                             Contamination definitely exists and a
                             site investigation has been performed.
Contact the appropriate federal, state,
local, or tribal government agencies
responsible for hazardous waste. Based
on feedback of the government agency,
identify the cleanup levels required for
redevelopment, and proceed to the
Investigate the Site phase.
Proceed to the Investigate the Site phase.
Proceed to the Investigate the Site phase.
Proceed to the Investigate the Site phase
if additional investigation is warranted;
otherwise, proceed to the Assess and
Select Cleanup Options phase.
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Assess the Site
                                                                                                    Brownfields Road Map
                                                                                                               llfcall.	
                                                                         EXAMPLE: Preliminary CSM
                                                                                                                .'CACHE LA
                                                                                                                ' POUDRE RIVER
                                                                                LLC.END  NOT TO SCALE
                                                                                                          POUDRE RIVf B SITE
                                                                                                        FORT COLLINS. COLORADO
A Conceptual Site Model is a graphical and written summary of what is
known or hypothesized about environmental contamination at a
brownfields site. An effective CSM is easy to understand and helps
technical teams, communities and stakeholders communicate with
each other and learn about the nature, extent, exposure and risk
associated with contamination. CSMs typically include graphical data
and written content, and may also include information such as site
features, geologic and hydrogeologic data, contaminant types,
transport and exposure pathways and potential receptors.
Benefits of CSM Use
CSMs are an important tool for the assessment and cleanup of
brownfields sites because they can assist stakeholders to:
   •  More fully understand site conditions and features
   •  Synthesize information from multiple sources
   •  Identify which information is unknown or uncertain about the site
   •  Define a plan for collecting additional information
   •  Obtain stakeholder agreement on site conditions and related project investigation, design and cleanup plans
Phases of the Project Life Cycle CSM
There are six phases of a life cycle CSM. It is important to understand that a life cycle CSM does not require the creation of six
individual CSMs, but rather the development of one CSM that evolves through all stages of site redevelopment. As additional
information about the site is known, the CSM becomes a powerful tool to support technical and communication needs.
 V   WATER TABLE (APPROXIMATE)
	7— BENZENE AND NAPTHALENE PLUME BOUNDARY
1   i  POST-PINEV CREEK ALLUVIUM (UPPER HOLOCENE)
!   i  BROADWAY ALLUVIUM (PLEISTOCENE!
I   A  PIERRE SHALE
I S S I  LAMOftU.
MHBI  CACHE LA POUDRE RIVER
                                                                                                          PRELIMINARY
                                                                                                       CONCEPTUAL SITE MODEL
                                                                                                          U.S. EPA REGION VIII
                                                                                                         IN COOPERATION WITH
                                                                                                    BROWNf IELOS TECHNOLOGY SUPPORT CENTER
    Project Life Cycle CSM Ph
         Preliminary
      Initial version of the
      CSM developed using
      existing data such as
      historical information,
      interviews with site
      owners, information
      from databases
      managed by third
      parties and other
      important background
      information.
                       A refined version of the
                       Preliminary CSM used
                       to identify data gaps
                       and areas where
                       uncertainties exist, such
                       as exposure pathways
                       and receptors. The data
                       gaps and uncertainties
                       serve as the basis for
                       developing detailed
                       plans for site
                       investigation.
Adds to the CSM
information obtained
during site
investigation, which is
used to help select
appropriate remedial
strategies and
technologies.



1 incorporates into the
CSM information at a
more detailed level, or
new considerations
that are identified, in
support of the
development of a
site-specific remedial
design.


^^^^^^^^^^^g
Information obtained
during remedy
implementation is
added, resulting in a
CSM that is used to
support efforts to
optimize remediation
effectiveness.



CSM includes
information obtained
from the construction
and completion of the
remedy, such as
contamination left on
site, institutional
controls (ICs) that have 1
been implemented and 1
monitoring
requirements.
                  Assess the Site

                                             Investigate the Site
                                                    T
                                              Assess and Select
                                              Cleanup Options  ^
                                                                           Design and Implement the Cleanup
            Road Map Steps: The six life cycle CSM phases relate to the general steps involved in the investigation and cleanup of a brownfields site.

  For More Information
  More details, including tools to assist in developing and using a CSM, and examples of CSMs, are available on the Triad
  Resource Center website (www.triadcentral.org/tech/dsp sub.cfm?id=13).
              jrces for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight csm.cfm.
22
                                           Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                                              Investigate the Site
Information collected during
the site investigation phase
supports future decisions
about potential cleanup
options and reuse
alternatives.
 Confirm Contamination and Identify its Source, Nature and Extent

 Activities conducted during the site investigation phase are focused on confirming
 whether any contamination exists at a site, locating the source of contamination,
 characterizing its nature and extent and identifying possible threats to the
 environment or to any people living or working nearby. For brownfields sites, the
 results of a site investigation are used to identify and quantify the risks associated with
 potential contamination and to develop effective cleanup plans. The results may also
 be used to set specific goals for the cleanup and assess anticipated cleanup costs,
 which will help stakeholders evaluate the economic viability of the project.
    ASTM International Phase II ESA
  Environmental site assessments are
  conducted to evaluate existing
  environmental problems from past
  operations and potential
  environmental problems from current
  or proposed operations at a site. The
  primary objective of conducting a
  Phase II ESA is to confirm and evaluate
  the RECs identified in the Phase I ESA.
  For more information about the ASTM
  International standard  practice, visit
  www.astm.org/Standards/E1903.htm
           A site investigation, also referred to as a Phase II ESA, is designed based on
           the results of the Phase I ESA discussed in the preceding chapter. The
           Phase II ESA includes the analysis of samples of building materials and
           environmental media, such as soil and soil gas, groundwater, surface
           water, sediment and  indoor air. For sites where contamination is
           confirmed, additional site investigation efforts are used to delineate the
           nature and extent, source locations and significance of contamination for
           the purpose of supporting subsequent cleanup and reuse decisions.
           Contaminant migration pathways through media (for example, soil,
           groundwater and air) are also examined in relation to potential receptors
           (for example, humans, animals and plants). A baseline risk assessment to
	|  quantify risk to human health and or the environment may be conducted.
 Examples of investigation technologies that may be useful during this phase are
 presented in  the online Guide to Contaminants and Technologies available at the
 Brownfields Road Map website.

 Many technologies are available to assist those involved  in brownfields cleanup to be
 more effective in their efforts. In addition, BMPs for site investigation and cleanup
 have emerged in the last few years. These BMPs incorporate systematic project
 planning, dynamic work strategies and the use of real-time measurement
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                                                            23

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Investigate the Site
                                                   Brownfields Road Map
technologies to accelerate and improve the cleanup process by reducing costs,
improving decision certainty, and expediting site redevelopment. For example,
effective systematic planning of the investigation can result in lower overall project
costs, while dynamic work strategies can reduce or eliminate the need for multiple
mobilizations to a site to complete investigations.

Real-time measurement technologies provide information about contamination at the
site that the project team can analyze while in the field. Used collaboratively with off-
site laboratory analysis, the real-time data and field-based analytical methods can
provide a more precise picture of the conditions at the site (for example, the extent of
contamination and migration pathways). See Spotlight 5, Data Quality: The Key to
Making Robust Site Decisions, for details about the benefits of using real-time
measurement tools and methods. A thorough site investigation will improve
understanding about the true conditions of the site, which reduces uncertainty and
improves stakeholder confidence in the decisions made.
                                               Types of Uncertainty

                                             Using BMPs helps to reduce a
                                             variety of uncertainties associated
                                             with brownfields projects.
                                              Analytical Uncertainty
                                               Methods, Quantity, Quality,
                                               Validation, Appropriate Use
                                              Sampling Uncertainty
                                               Media, Methods, Location,
                                              Distribution, Depth, Purpose
                                             Site Decision Uncertainty
                                               Risk, Action Levels, Remedy,
                                               Stakeholders, Acceptability
                                               Resource Uncertainty
                                              Funding, Schedule, Personnel,
                                                  Logistics, Weather
Provided below is an overview of using BMPs to investigate a brownfields site and the
benefits of their use.
                        Best Management Practices for Investigating a Brownfields Site
                                   Linking Decisions, Data and Technologies
              Decisions to be Made
                 Project Planning
            and Technical Performance
 Project Life Cycle CSM
   Preliminary Planning
   • What are the site redevelopment goals?

   Systematic Planning
   • What decisions are needed to support site goals?
   • What information is needed to make decisions?
   • What level of data quality is required?
   • What data gaps or uncertainties exist?

   Work Plan Development
   • How should data be collected?
   • What are the appropriate sampling and analysis
    designs to generate data of acceptable quality?
   • Can real-time measurement technologies be used
    to collect data at the level of quality required?

   Investigation Using Dynamic Work Strategies
   • What do the data indicate?
   • Is the delineation of contamination complete?
   • Can robust decisions be made?
               Preliminary Planning
Create CSM (Preliminary)
               Systematic Planning
 Update CSM (Baseline)
             Work Plan Development
            Based on data gaps identified
                in the Baseline CSM
               Investigation Using
             Dynamic Work Strategies
            Conduct additional dynamic
               sampling as needed
              Investigation Complete
              Take appropriate action
            based on the decisions made.
     Update CSM
(Characterization Stage)
 Update CSM to support
remedy selection, design
  and implementation
   Benefits of Using BMPs
   • Improved site investigation information to support better redevelopment decisions
   • More effective communication with stakeholders and the local community
   • Increased confidence (reduced uncertainty) that cleanup plans are protective of human health and the environment
   • Achievement of cleanup goals faster and at lower cost
24
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Brownfields Road Map
                        Investigate the Site
      Spotlight  5
             Data Quality: The Key
       to Making Robust Site Decisions
  Successful brownfields projects rely on environmental data that accurately
  represent actual site conditions. These data must be of defensible quality and
  provide sufficient detail to support robust decision-making so that a brownfields
  project can proceed in a manner acceptable to all stakeholders and in accordance
  with government regulatory and oversight programs (for example, EPA quality
  assurance and state voluntary cleanup programs). Thus, data quality should be
  considered during each redevelopment step, from determining the extent of
  contamination and assessing risks to implementing the  best cleanup approach.
  Planning for Data Quality
  Planning efforts for a brownfields project should address factors that affect data
  quality, such as sampling design, sampling methods, analytical methods and
  quality assurance/quality control (QA/QC) protocols. To  ensure that defensible
  quality data are collected, initial planning activities for brownfields projects should include:
    •  Clarifying project and data quality objectives (DQO)
    •  Identifying decisions and relevant supporting data that will be necessary to support project completion
    •  Developing a CSM to understand site conditions and identify key site data gaps
    •  Achieving consensus from project stakeholders on strategies and methods for data collection, evaluation and use

  Using Field-based Methods to Reduce Site Uncertainty
  Understanding the true conditions of the brownfields site reduces site
  uncertainty—which is the key to making successful decisions. Increased
  decision confidence among site owners, buyers and surrounding
  communities decreases the likelihood of errors and omissions that could
  negatively affect the site later. However, the cost of reducing uncertainty can
  vary considerably based on the contaminants of concern and the
  technologies and methods used to generate data.
  Using real-time direct sensing tools and field-based analytical methods may
  be a cost-effective way to reduce site uncertainty. They increase sampling
  density and precision by enabling lower per-measurement costs than sole
  reliance on conventional sampling and laboratory analysis methods. These
  tools and  methods can also increase the quality and value of conventionally
  derived data by ensuring that samples are collected from the appropriate
  locations, thereby increasing the representativeness of those samples. Project
  teams can use data collected with field-based methods to make timely
  decisions  rather than waiting weeks to months for laboratory results and
  formal project report generation.
  For each brownfields project, steps should be taken to confirm that the field-
  based methods to be used on the project site will provide adequate data quality to support decision-making. In addition,
  results from field-based sensing and analytical methods should be confirmed using appropriate laboratory analytical methods.

  For More Information
  Information about data quality is available at www.triadcentral.org/req, including an overview of key concepts and
  considerations for using real-time measurement systems. Additional resources are provided by the Interstate Technology and
  Regulatory Council (ITRC) Incremental Sampling Methodology Team (www.itrcweb.org/teampublic ISM.asp) and the ITRC
  Sampling, Characterization and Monitoring  Team (www.itrcweb.org/teampublic SCM.asp).
    gnug
         Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_dq.cfm.
    nfields
i
Reduce uncertainty and
improve understanding of
site conditions with greater
sampling density

Offer lower
per-measurement costs
than conventional
sampling and laboratory
analysis

Support real-time decision
making rather than waiting
for laboratory results and
formal reports

Increase decision
confidence of stakeholders
      Real-time is within a time frame that allows the project
      team to react to the information while in the field.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                       25

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Investigate the Site
                                                 Brownfields Road Map
Conduct Your Site Investigation
                                           Consider These Questions
The following activities are typically conducted during the site investigation phase.
Intended as a general planning guide, the list is not a comprehensive inventory of all
site investigation activities required under state and federal regulations. Factors to be
considered while planning the site investigation are presented in the margin in the
form of questions.

    •   Contact the EPA regional brownfields coordinator to explore the potential for
       the project to qualify for a brownfields assessment grant and options for
       technical assistance through the EPA's TBA program.

    •   If a Phase II ESA is warranted, consider funding sources (such as state
       brownfields programs and federal tax deductions) for site investigation and
       cleanup activities:
       o   Contact your state's brownfields program representative and the EPA
           regional brownfields coordinator to identify the availability of state and
           EPA support programs and federal financial incentives.

    •   In collaboration with stakeholders, use the results of the Phase I ESA to update
       the project life cycle CSM. Identify critical data gaps as the basis for the design
       of a Phase II ESA.
    •   Continue to work with regulatory agencies during the site investigation design
       and data collection phases to ensure that regulatory requirements are being
       properly addressed:
       o   Identify and consult with the appropriate federal, state, local and tribal
           agencies  to include their input as early as possible in the project.

    •   Invite community members to participate in discussions about the project
       goals and objectives and  in decisions about the site investigation design.

    •   Identify the proper mix of real-time measurement technologies and
       conventional methods (such as off-site laboratory analysis) to investigate the
       site and meet the required level of data quality.

    •   Research and ensure that proposed real-time measurement technologies and
       the off-site laboratory can accurately detect all contaminants of interest to a
       concentration that is lower than or comparable to the screening level
       concentrations defined by the regulatory guidance and the agencies
       overseeing the project.

    •   Conduct a Phase II ESA to define the environmental conditions associated with
       the identified RECs at the site:
       o   Identify potentially viable site  sampling and testing methods to confirm
           geological and hydrogeological site conditions. For example, consider
           consulting with a geophysical  survey service provider to evaluate
           approaches for cost-effectively addressing data gaps.
       o   Confirm and refine as necessary the human health and ecological
           pathways for exposure to site contaminants.
                                          Goals and Planning
                                          » Can the need for cleanup be
                                           assessed accurately from the
                                           site assessment or from a
                                           previous site investigation?
                                          » Who or what could be
                                           affected by the
                                           contamination or cleanup
                                           efforts?
                                          » What happens if
                                           contamination poses a
                                           "significant threat" to local
                                           residents?
                                          » What happens if the
                                           contamination is originating
                                           from an adjacent property
                                           or other off-site source?
                                          » What happens if sampling
                                           indicates that
                                           contamination is originating
                                           from a naturally occurring
                                           source?


                                          Oversight
                                          » Will the site be entered into
                                           astateVCP?lfso,willthe
                                           investigation plan be
                                           reviewed through the VCP?
                                           If not, are there applicable
                                           federal, state, local and tribal
                                           regulatory requirements?
                                          » What agency will oversee
                                           the investigation? Does the
                                           agency have suitable
                                           standards or guidelines for
                                           the proposed reuse?


                                          The Community
                                          » What issues has the
                                           community raised that may
                                           affect the site investigation?
                                          » How will the results of the
                                           site investigation be shared
                                           with the community?
26
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Brownfields Road Map
                                                               Investigate the Site
  Consider These Questions
        (continued)


Site Conditions
» What are the potential
  exposure pathways?
» Are the infrastructure
  systems (roads, buildings,
  sewers, public water
  systems and other facilities)
  contaminated? Could they
  be affected by efforts to
  clean up contamination?
» Is the site likely to be a
  "challenging cleanup"? See
  Spotlight 8 on page 35.


Options
» Has the team explored the
  full range of technologies
  that can produce data of the
  quality required?
» What real-time technologies
  are available to facilitate site
  investigation and support
  data collection efforts?
» Can the technologies
  selected limit the number of
  mobilizations to the site?
» Will the site investigation
  involve iterative steps to
  address data gaps that arise
  during the project?
       o   Delineate the nature, extent, source and significance of any contamination
           confirmed to be present.
       o   During the field investigation, evaluate results with other stakeholders to
           achieve consensus that the associated data needs at each identified
           release have been addressed.
       o   If applicable, evaluate whether and how the infrastructure systems (for
           example, roads, sewers and structures) are affected by contamination.

    •   Update the Baseline CSM with data and observations obtained during the site
       investigation. Use the Characterization CSM to identify and evaluate potential
       cleanup options.

    •   Assess the risks posed to human health and the environment. Depending on
       the planned end use of the property, other potential exposure pathways or
       sensitive receptors may also require evaluation. Consider the human exposure
       pathways of direct contact, ingestion, or inhalation of soil and dust, water and
       indoor air.
    •   Depending on state regulatory requirements, perform a risk assessment to
       identify site-specific cleanup levels when contaminant concentrations
       confirmed at the site exceed regulatory screening levels.
    •   Evaluate confirmed site contamination in all affected environmental media in
       terms of overall cleanup costs, including initial actions and long-term
       operation and maintenance. Include potential cleanup options and
       constraints that may affect redevelopment requirements, such as project
       schedules, costs and potential for achieving the desired reuse.

    •   Share the updated CSM with members of the community to promote
       understanding of the site conditions.
Find Helpful Resources
                                       Visit the Brownfields Road Map website to identify and review resources
                                       and tools that provide details about technology applications, methods and
                                       other site-specific concerns.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                                                             27

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Investigate the Site
                                                   Brownfields Road Map
Plan Your Next Steps

The next course of action is determined by the results of the site investigation. Several
possible outcomes and subsequent courses of action are explained below.
Result of the Site Investigation
No contamination is found.
Course of Action
Consult with appropriate regulatory officials
before you proceed with redevelopment
activities.
Contamination is found, but does
not pose a significant risk to human
health or the environment.
Cleanup of the contamination found
probably will require a small
expenditure of funds and time.
Consult with appropriate regulatory officials
before you proceed with redevelopment
activities.
Proceed to the Assess and Select Cleanup
Options phase.
Cleanup of the contamination
probably will require a significant
expenditure of funds and time.
Residual contamination is
determined not to pose a risk to
local residents or the environment.
Determine whether redevelopment
continues to be practicable as planned, or
whether the redevelopment plan can be
altered to fit the circumstances; if so, proceed
to the Assess and Select Cleanup Options
phase.
Contamination is found that poses a
risk to local residents or the
environment.
Contact the appropriate federal, state, local or
tribal government agencies responsible for
hazardous waste. Compliance with other
programs, such as the EPA's RCRA and
Superfund programs, may be required.
28
    Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                                                                               Investigate the Site
      Spotlight 6
       High-Resolution Site Characterization and In Situ
           Technologies Promote Effective Cleanups

                                    The advent of innovative site characterization technologies and strategies and the
                                    development of more effective treatment methods may provide brownfields
                                    stakeholders with new options for faster and more effective site cleanup.
                                    New approaches to site cleanup, based on the use of in situ treatment technologies,
                                    promote more targeted or "surgical" options for cleanup by enabling a better
                                    understanding of subsurface features, contaminant distribution, volume, mass and
                                    behavior over time.
       High-resolution site
     characterization (HRSC)
  strategies and techniques define
   contaminant distributions in
    environmental media with
        greater certainty.

Benefits of In Situ Treatment
Treatment using in situ methods reduces the time required
to clean up a site, decreases the amount of residual
contamination left at sites and minimizes the need for
long-term operations and maintenance. Together, these
benefits directly serve the interests of brownfields
stakeholders by:
   •  Expediting site redevelopment and reuse
   •  Reducing the requirement for engineering controls
     (EC) and ICs
   •  Lowering or eliminating long-term expenditures
     related to environmental protection measures
In situ treatments also provide the added value of supporting the goals of greener cleanups. For example, in situ treatments
reduce the amount of treatment materials and waste generation and handling.
                                                                                       3-D visualization of groundwater
                                                                                      contamination at a brownfields site
Why High-Resolution Site Characterization?
Design and implementation of in situ remedies requires an accurate
understanding of the nature and extent of subsurface
contamination, which can most efficiently and reliably be defined
using HRSC strategies and technologies. In addition, HRSC data can
be used to support the initial evaluation and selection of in situ
treatment technologies.
HRSC supports more effective  use of in situ remedies by:
   •  Characterizing subsurface conditions critical to successful
     remedy design at a scale that conventional investigation
     methods are unable to attain
   •  Providing greater confidence that a site is fully characterized
     by increasing data density
   •  Enabling more accurate estimation of contaminant mass and
     volume through tighter source identification and delineation
   •  Improving the cost and  performance of remedy monitoring by minimizing monitoring network needs.
Asa targeted strategy or as an overall BMP, HRSC can be applied to sites of any size under any regulatory program.

For More Information
HRSC is a new EPA initiative, and a formal definition for HRSC strategies and technologies has not yet been finalized. The
general concept and benefits of HRSC are being explained and communicated through a variety of EPA efforts. Technical
resources and other information about HRSC are available at www.brownfieldstsc.org/topics.cfm.
        Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_hr.cfm.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Investigate the Site
                                                     Brownfields Road Map
                                                                                       IDDDDI
                                                                                       EDJ
                                                                                       crawl space
                                                           DDDD
                                                           Dn_D
                                                             slab
                                basement
                                 intrusion through cracks, holes, and gaps
                                                                                     vapor migration
                                                                             contaminated soil

                                                                                 VOCs
                                                       T water table

                                                    contaminated
                                                    groundwater
Vapor Intrusion (VI) occurs when toxic vapors enter structures, become
concentrated and contaminate the indoor air. The vapors, which come
from chemicals in contaminated soil or groundwater, migrate through
foundation cracks, fractures in basement floors or walls, crawl spaces and
small gaps around pipes and utility lines. VI poses potential chronic and
acute health risks to anyone who breathes the air inside the affected
buildings.
Many contaminants can cause VI, including chemicals that readily
evaporate (volatile) and those that evaporate more slowly (semivolatile).
Vapor-causing  contaminants are commonly referred to as volatile organic
compounds (VOCs). Examples of VOCs include gasoline, degreasers, dry-
cleaning solvents, naphthalene and some pesticides.
VI should be evaluated for all brownfields projects with possible VOC
contamination in the subsurface of the property or in the subsurface of nearby property. Because contaminated vapors can
migrate laterally in the soil and groundwater, the source does not need to be on the property to create a VI risk. Even green
spaces or properties with no history of industrial activity may be affected by VI if located near a contaminated property. Typical
brownfields sites with VI concerns include former gas stations, dry cleaners, landfills, automobile repair shops and former
manufacturing and chemical processing plants.

Considerations for Brownfields Projects
   •  Evaluating the potential for VI should begin early in the site assessment and investigation phases. Often, the only way VI
      concerns can be solved is to adequately evaluate them before cleanup begins. Solutions may be easier to implement
      and are generally less expensive if VI concerns are evaluated before construction is complete.
   •  The movement of volatile vapors can be difficult to quantify and initial environmental site assessments may not
      accurately identify VI concerns. If a potential VI risk exists, appropriate sampling should be conducted during the site
      investigation to evaluate potential exposure pathways.
   •  VI concerns should be incorporated into the project life cycle CSM to help define data quality objectives and identify
      considerations for the cleanup design.
   •  Strategies to reduce or eliminate indoor air contaminant risks include:
      o   Remediating or controlling the sources of contamination in the subsurface
      o   Increasing natural building ventilation
      o  Ventilating the affected buildings with properly operated heating, ventilation and air conditioning systems
      o   Restricting the use of the facilities of concern
      o  Changing the location or altering the design of future buildings
   •  Operations, maintenance and monitoring of mitigation systems are generally necessary.
   •  Some states have specific VI guidance; environmental agencies should be consulted to ensure that up-to-date and
      appropriate guidance is followed.

For More Information
 In 2008, the EPA's Brownfields and Land Revitalization Technology Support Center published Brownfields Technology
 Primer: Vapor Intrusion Considerations for Redevelopment. This primer contains detailed information about assessing
 and mitigating VI concerns that will help stakeholders communicate with technical experts and contractors.
 The EPA's VI website, www.epa.qov/oswer/vaporintrusion/, provides basic information and policy, guidance and technical
 documents. VI resources also are provided on the CLU-IN website at www.clu-in.org/issues/default.focus/sec/Vapor Intrusion/.
    ™  Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight  vi.cf
30
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                                 Assess and Select Cleanup Options
 The purpose of evaluating
 various cleanup alternatives is
 to identify technologies with
 the capability to meet specific
 cleanup and reuse objectives.
    Identifying the Best Options
     for Challenging Cleanups
  The cleanup of some brownfields
  sites may be complicated by site
  conditions and the specific
  contamination found on or near
  the property. See Spotlight 8,
  Challenging Cleanups,fora more
  detailed discussion.
Evaluate Applicable Cleanup Alternatives for Your Site

Data collected during the site assessment and investigation phases are critical for
moving to this phase of a brownfields project. The project team and stakeholders use
the data and information known about a property to review and evaluate cleanup
options applicable to specific site conditions and consistent with cleanup and reuse
goals. Continuing to use  the BMPs discussed in the previous sections ensures that
stakeholders can contribute meaningfully to the decision-making process because
they understand the site  conditions and potential risks.
Sharing details about the options under consideration and inviting comment from
those in the community likely to be affected by the cleanup and reuse is an important
activity and contributes significantly to long-term community acceptance and support
       of the selected cleanup alternative and the overall reuse goals. Encouraging
       community involvement in these decisions ensures that the approaches taken
       to address environmental impacts remain consistent with stakeholders' goals
       and objectives.
      After discussion and efforts to reach consensus among the various
      stakeholders, decisions are made about the selection of cleanup alternatives,
      including the use of technologies with the capability to meet specific cleanup
      and redevelopment objectives. For brownfields sites, it also is important to
frame these discussions and decisions around budget considerations and work
schedule constraints so that the project remains financially viable.

Institutional controls are another important consideration during this phase. Examples
of these legal and administrative tools include easements, covenants, zoning
restrictions and posting advisories to increase community awareness of the
environmental conditions and cleanup activities at the site. See Spotlight 9,
Understanding the Role of Institutional Controls at Brownfields Sites, for more
information about institutional controls.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                                                           31

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Assess and Select Cleanup Options
                                                 Brownfields Road Map
Selecting the Cleanup Options for Your Site
                                           Consider These Questions
The following list identifies activities that are typically conducted during the evaluation
and selection of cleanup options. The list is intended as a general planning guide and is
not a comprehensive inventory of all activities to be undertaken during this phase.
Factors to be considered are presented in the margins in the form of questions.

    •   Establish cleanup objectives that consider the end use and use applicable
       standards, published state or federal guidelines, risk-based corrective actions
       (RBCA), or site-specific risk assessment results.

    •   Communicate information about the proposed cleanup option to brownfields
       stakeholders, including members of the affected community. Solicit the input
       of the community in the site cleanup selection process and actively engage
       community members in decision-making.

    •   Review general information about cleanup technologies and approaches to
       become familiar with those  that may be applicable to the contaminants and
       geologic and hydrogeologic conditions present at the site. Focus on
       identifying  cleanup options that have a  proven track record for sites with
       similar contaminants and conditions:
           o   Use the resources available on the Brownfields Road Map website to
               identify technologies.
           o   See Appendix A, Guide to Contaminants and Technologies, at the
               Brownfields Road Map website for examples of technologies that are
               appropriate for specific types of contaminants.
           o   Search existing literature that further describes the technology
               alternatives.
           o   Analyze detailed technical information about the applicability of
               technology alternatives.

    •   Enlist the help of a  professional environmental practitioner with experience in
       applying these technologies at similar sites.

    •   Assess the need for using ICs as part of the cleanup approach.
    •   Narrow the list of potential cleanup options that are most appropriate and
       compatible for addressing site contamination and proposed reuse:
           o   Network with other brownfields stakeholders and environmental
               practitioners to leverage their expertise.
           o   Determine whether sufficient data are available to support
               identification and evaluation of cleanup alternatives.
           o   Analyze in more detail the applicability of technologies to the
               contamination and conditions identified at a site.
           o   Evaluate the options against a number of key factors, including their
               effectiveness, implementability  and cost.
           o   Consider the benefits that some cleanup options may offer; for
               example, less disruption to the community, potential reduction of
               liability and long-term sustainability.
                                         Goals and Planning
                                         » Is there a consensus that site
                                           characterization
                                           uncertainties have been
                                           sufficiently reduced?
                                         » How is the appropriate and
                                           feasible level of cleanup
                                           identified?


                                         Oversight
                                         » Are there federal, state, local
                                           or tribal cleanup
                                           requirements?
                                         » Are there prescribed
                                           standards for the cleanup?
                                         » Is there a state
                                           environmental insurance
                                           program?


                                         The Community
                                         » How can the community
                                           participate in the review and
                                           selection of options?
                                         » What environmental
                                           standards should be
                                           considered to ensure that
                                           community stakeholders are
                                           satisfied with the outcome
                                           and process of the cleanup?
                                         » Are cleanup options
                                           acceptable in light of
                                           community concerns?
                                         » Are cleanup options
                                           compatible with regional or
                                           local planning goals and
                                           requirements?


                                         Site Conditions
                                         » Should risk-based
                                           approaches be considered
                                           for addressing exposure?
                                         » Will the cleanup facilitate or
                                           hinder the planned
                                           redevelopment?
                                         » Is there a need for ICs after
                                           cleanup? If so, will ICs
                                           facilitate or hinder
                                           development?
32
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Brownfields Road Map
                                                   Assess and Select Cleanup Options
  Consider These Questions
         (continued)


Options
» Are the options acceptable
  in light of community
  concerns about protection
  and reuse of the site?
» Are the cleanup options
  compatible with regional or
  local planning goals and
  requirements?
» What are the short-and
  long-term effects of the
  cleanup technologies under
  consideration?
» What options are available
  to monitor the performance
  of cleanup technologies?
» Are proposed ICs
  appropriate in light of
  community concerns?
» What plans, including
  financial assurances, are
  being made to ensure that
  ICs remain functional as
  long as contamination is
  present?
» Does the proposed cleanup
  approach place burdens on
  future land owners or
  occupants?


Funding
» How long will cleanup take?
» What will cleanup cost?
» Will schedule constraints or
  the estimated cost adversely
  affect the project's viability?
» Who will pay for long-term
  costs to maintain the
  cleanup, including any ICs?
           o   Determine the effects of various technology alternatives on
               redevelopment objectives.
    •   Continue to collaborate with regulatory agency stakeholders to ensure that
       regulatory requirements are properly addressed:
           o   Confirm that the agencies concur that site characterization
               uncertainties have been sufficiently reduced to allow the process of
               remedy selection and design to begin.
           o   Obtain agency input regarding the range of cleanup options under
               consideration and input regarding any additional options.

    •   Contact the EPA regional brownfields coordinator to explore the potential for
       the project to qualify for a brownfields cleanup grant or TBA support.
    •   Integrate cleanup alternatives with reuse alternatives to identify potential
       constraints on reuse and time schedules and to assess cost and risk factors.

    •   To provide a measure of certainty and stability to the project, investigate
       environmental insurance policies, such as protection against cost overruns,
       undiscovered contamination and third-party litigation, and integrate their cost
       into the project financial package.

    •   Select an acceptable remedy that not only achieves cleanup goals and
       addresses the risk of contamination, but also best meets the objectives for
       redevelopment and reuse of the property and is compatible and sustainable
       with the needs of the community.

Find Helpful Resources
          Visit the Brownfields Road Map website to identify and review resources
          and tools that provide details about technology applications, methods and
          other site-specific concerns.
A wide variety of chemical contaminants may be present at brownfields sites. Use the
online Guide to Contaminants and Technologies, available at the Brownfields Road
Map website, to get detailed
information about the applicability
of technologies for particular types
of brownfields sites. The table on
the following page lists examples of
brownfields sites and
   Site Types
Which contaminants
 are associated with
 brownfields sites?
                             treatment technologies that are
                             described in the online guide.
                                                    Investigation
                                                    Technologies
                                                 What technologies may
                                                 be used to investigate
                                                    contamination?
                                            Contaminant
                                              Groups
                                            What types of
                                          contamination are
                                          found and treated?
                                                                   Treatment
                                                                  Technologies
                                                                What technologies
                                                               may be used to treat
                                                                 contamination?
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map


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Assess and Select Cleanup Options
                                                        Brownfields Road Map
                          Examples of Brownfields Site Types and Treatment Technologies
                     Site Activities and
            ^^^^^^^^•^^^^^^^^^^^^^^H
  Agricultural
  Battery recycling and disposal
  Chemical and dye manufacturing
  Chlor-alkali manufacturing
  Cosmetics manufacturing
  Drum recycling
  Dry cleaning
  Gasoline stations
  Glass manufacturing
  Hospitals
  Incinerators
  Landfills, municipal and industrial
  Leather manufacturing
  Machine shops and metal fabrication
  Manufactured gas plants and coal
  gasification
  Marine maintenance
  Metal plating and finishing
  Metal recycling and automobile salvage
  Mining and mine-scarred lands
  Operations*
    • Painting and automobile body
     repair
    • Pesticide manufacturing and use
    • Petroleum refining and reuse
    • Pharmaceutical manufacturing
    • Photographic film
     manufacturing and development
    • Plastic manufacturing
    • Printing and ink manufacturing
    • Railroad yards
    • Research and educational
     institutions
    • Semiconductor manufacturing
    • Smelter operations
    • Underground storage tanks
    • Vehicle maintenance
    • Wood preservation
    • Wood pulp and paper
     manufacturing
 e Depending on the type of site, level of contamination and risks posed, these
  sites may be subject to other laws and regulations other than state VCPs, and it
  may not be appropriate to manage them through the brownfields programs.
  Check with EPA or the state on a site-specific basic to ensure assessment and
  cleanup are conducted in accordance with the applicable statutory and
  regulatory authorities.
    reatment Technologies (Media)
Air Sparging (G)
Bioremediation (G/S)
Chemical Treatment (G/S)
Electrokinetics (G/S)
Flushing (G/S)
Incineration (S)
In-Well Air Stripping (G)
Mechanical Soil Aeration (S)
Multi Phase Extraction (G/S)
Nanoremediation (G/S)
Open Burn/Open Detonation (S)
Permeable Reactive Barrier (G)
Physical Separation (S)
Phytoremediation (G/S)
Pump and Treat (G)
Soil Amendments (S)
Soil Vapor Extraction (S)
Soil Washing (G/S)
Solidification/Stabilization (S)
Solvent Extraction (S)
Thermal Desorption (S)
Thermal Treatment (in situ) (G/S)
Vitrification (S)
                                    G - Groundwater, leachate and surface water
                                    S - Soils, sediments and sludges
           Use the online Guide to Contaminants and Technologies to obtain more
           details about the applicability of technologies at brownfields sites.
Plan Your Next Step

After cleanup options have been selected for your site, consider the following options:
 Result of the Review of Cleanup
 Options
 The proposed cleanup option
 appears feasible.
 No cleanup option appears
 feasible in light of the proposed
 redevelopment and land reuse
 needs (such as project milestones,
 cost and intended reuse).
Course of Action
Proceed to the Design and Implement the
Cleanup phase.
Determine whether revising the redevelopment
plan remains a practicable option; if so, proceed
to the Design and Implement Cleanup phase.
Compliance with other programs, such as the
EPA's RCRA and Superfund programs, may be
required.

                                         Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map

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Brownfields Road Map
                                         Assess and Select Cleanup Options
        Challenging Cleanups
n
  The cleanup of some brownfields sites can be challenging
  because the property is contaminated with chemicals that
  are highly mobile, hard to find or difficult to treat.
  Contaminants may be hard to clean up because:
    • They are difficult to capture or separate
    • They are located in hard-to-reach areas (for example,
      fractured bedrock)
    • They do not degrade naturally in the environment
  Combinations of these factors present a variety of
  challenges during site characterization and cleanup, which
  can result in additional costs and time throughout a
  brownfields project.

  Types of Brownfields Sites with Challenging Cleanups
  Many brownfields sites — including former gas stations,
  electronics manufacturing facilities, auto service centers,
  dry cleaning facilities, electroplating plants, wood
  preservation sites and manufactured gas plants — have
  been affected by contaminants that are challenging to
  investigate and clean up. Some of the common
  contaminants found at these types of brownfields sites
  include dense non-aqueous phase liquids (DNAPLs),
  polychlorinated biphenyls (PCBs), dioxins/furans, 1,4-
  dioxane, methyl tertiary butyl ether (MTBE), perchlorate
  and arsenic.

  Assessment Considerations and Cleanup Options
  Site assessment and cleanup should be designed with
  strategies and technologies that address the unique nature
  of the contaminants of concern. A solid understanding of
  contaminant behavior in the environment is critical to
  designing and implementing effective assessment and
  cleanup. For example, contaminants that are hazardous at
  very low concentrations may require costly, time-intensive
  laboratory analysis to detect, as compared with
  contaminants at higher concentrations, which might be
  well-suited for assessment using cost-effective screening
  technologies.

  For More Information
  The EPA provides reports and other informational materials
  about various contaminants on the Contaminant Focus
  section of the EPA's Contaminated Site Clean-Up
  Information  (CLU-IN) website at
  www.cluin.org/contaminantfocus.
               EXAMPLE: A Closer Look at DNAPLs
               Two factors make DNAPLs a contaminant that is difficult to clean
               up: (1) they do not easily dissolve in water (they are only slightly
               soluble) and (2) they are heavier than water. Being denser than
               water, DNAPLs tend to sink through groundwaterand permeate
               into fine-grained soil units such as silt and clay. DNAPLs also can
               migrate in multiple directions through fractures in bedrock.
               Because of these properties, it can be difficult to predict DNAPL
               migration pathways. Subsequently, DNAPLs in bedrock and fine-
               grained soils can act as continuing sources of contamination,
               which may cause long-term impacts to groundwater and pose a
               significant challenge to site cleanup.
               Used alone, traditional pump-and-treat systems may require
               years to decades to clean up the groundwater. In these cases, it
               is important to consider more effective alternatives, either
               individually or in combination ("treatment train" or "combined
               remedy"). Examples of such treatments include:
                 •  Using microorganisms to break down the contamination
                   (bioremediation)
                 •  Extracting DNAPL compounds from soil in vapor form with
                   a vacuum system and treating the gas to remove the
                   contaminants (soil vapor extraction [SVE])
                 •  Applying chemicals to the contamination to break down
                   the DNAPLs into nonhazardous compounds such as water
                   and carbon dioxide (in situ chemical oxidation injection)
                                       DNAPLs: A Significant Challenge
                               DNAPLs migrating through
                                  unsaturated deposits
.water table
                                                      groundwater flow
                      Dissolved DNAPLs sinking
                     through saturated deposits
                  DNAPLs and dissolved DNAPLs migrating into bedrock
         Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight_cc.cfm.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Assess and Select Cleanup Options
                                                    Brownfields Road Map
   I Spotlight  9  1
       Understanding the Role of Institutional Controls
                       at Brownfields Sites
 Institutional controls are a broad spectrum of administrative and legal
 tools used to help minimize the potential for exposure to residual
 contamination and to protect physical cleanup measures at
 contaminated sites. ICs work by limiting land or resource use or by
 providing information that helps modify or guide human behavior at a
 site. ICs normally supplement ECs and are typically used in conjunction
 with the overall cleanup remedy to support reuse. Long-term
 considerations associated with 1C use, such as impacts on reuse and
 funding requirements, must be carefully weighed against the costs and
 benefits of permanent removal of contamination.

 Types of ICs

    • Proprietary controls involve private agreements that impose
     restrictions on, or otherwise  affect the use of, a property. Common
     examples of proprietary controls are covenants, deed  restrictions
     and easements.

    • Governmental controls, such  as zoning, building codes,
     groundwater use regulations and commercial fishing bans, restrict
     land or resource use by the authority of a government entity.
                          Institutional Controls are
                          Administrative and Legal Tools
                                Types of ICs

                             •H Proprietary Controls
                                Governmental Controls
                                Enforcement and Permit Mechanisms
                                Informational Tools
                          Objectives of ICs
                          Minimize potential exposure to contamination
                          Restrict land use activities that might
                          compromise cleanup efforts
    •  Enforcement and permit tools with 1C components typically involve administrative orders, consent decrees and permits to
      limit certain activities at a site or require a specific activity, such as monitoring and reporting.

    •  Informational devices, such as signs, markers and community outreach activities, provide notification and may
      communicate risks about residual contamination that may remain on a site after a cleanup remedy has been undertaken.

 Long-Term Considerations

    •  Identify the long-term costs and administrative implications of maintaining and enforcing ICs.

    •  Evaluate the potential use of ICs early in the cleanup process to plan appropriately for implementation, maintenance and
      enforcement challenges.

    •  Consider and compare the costs of leaving contamination in place while maintaining ICs to the costs associated with
      treating or removing contamination.

 For More Information
 The EPA's interim final guidance, "Institutional Controls: A Guide to Planning, Implementing, Maintaining, and Enforcing
 Institutional Controls at Contaminated Sites," was published in the Federal Register in 2010 to request public comment. In 2009,
 the EPA released a fact sheet that provides general information about the costs of ECs and ICs at brownfields sites. The fact
 sheet, which includes an example of the use of ICs as part of a site cleanup, is available online at www.epa.gov/brownfields/
 tools/Its cost fs.pdf. Another EPA fact sheet, "Addressing Long-Term Stewardship: Highlights from the Field," provides three
 examples that highlight long-term considerations for maintaining and enforcing ICs. It can be viewed online at
 www.epa.qov/brownfields/tools/lts fs 04  2008.pdf.
        Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight  ic.cfm.
36
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Brownfields Road Map
                                                 Design and Implement the Cleanup
 The final phase of preparing a
 brownfields property for
 reuse is designing and
 implementing the cleanup.
 During this phase, the
 discovery of additional
 contamination may require
 further site investigation or
 reassessment of available
 cleanup options.
 Maintaining stakeholder
 participation during cleanup
 promotes long-term
 community acceptance and
 support of the planned reuse
 of the brownfields site.
Develop and Carry Out Your Detailed Cleanup Plans

During the cleanup design and implementation phase, the property is prepared for
redevelopment and reuse by carrying out the selected cleanup options, as described
in the preceding chapters. The design of the cleanup plan and implementation of the
chosen remedies involves close coordination with all other redevelopment efforts in
the immediate vicinity of the site.

Building on the comprehensive understanding of site conditions that has evolved
during the project, real-time technologies and dynamic work strategies can be used to
monitor and assess the results of cleanup activities. As in the site investigation phase,
these field-based methods can be used to evaluate progress toward the achievement
of the cleanup goals. Precise monitoring data help to minimize uncertainty and form
the basis for long-term monitoring strategies, including the use of institutional
controls.

In some cases, implementing the cleanup may lead to the discovery of additional
contamination or may reveal other complicating factors that require the project team
to conduct further site investigation and characterization. Additional site investigation
results may demonstrate that no practical alternatives exist for cleaning up the site to
meet the reuse goals of the project; if so, the site owner may need to consider
modifying the proposed land reuse plan or identifying other land use alternatives. See
Spotlight 8, Challenging Cleanups, for details about sites affected by contaminants
that are difficult to investigate and clean up.

Design and Implement Your Cleanup

Typical activities that may be conducted during this phase are outlined below, along
with factors to consider. The list is intended as a general planning guide and is not a
comprehensive inventory of all activities to be undertaken during cleanup of a
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                                                           37

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Design and Implement the Cleanup
                                                 Brownfields Road Map
brownfields site. Factors to be considered are presented in the margin in the form of
questions.

    •   Review all applicable federal, state, local and tribal regulations and regulatory
       guidelines to identify all specific requirements, including guidelines for state
       VCPs.

    •   Continue to engage regulatory stakeholders to ensure that regulatory
       requirements are being properly addressed:
           o  Confirm that the agency concurs with the design of the selected
              remedy.
           o  Obtain agency input and concurrence on remedy assessment metrics
              and alternative exit strategies.

    •   Contact the state brownfields program and the EPA regional brownfields
       coordinator to identify and determine the availability of state and EPA support
       programs.

    •   Develop conceptual plans for cleanup and subsequent monitoring that
       incorporate technology options and consider the effect of any cleanup
       activities on the proposed reuse of the property and the schedule for project
       design or construction:
           o  Develop or review the schedule for completion of the project.
           o  Obtain a final amount for the grant funding available for project
              development.
           o  Coordinate renovation and construction of infrastructure with cleanup
              activities.
           o  Coordinate activities with developers, financiers, construction firms
              and members of the local community.

    •   Establish contingency plans to address the discovery of additional
       contamination during cleanup, including tools such as environmental
       insurance policies.

    •   Continue to maintain stakeholder consensus and active community
       participation during cleanup:
           o  Conduct public outreach meetings on a regular basis.
           o  Provide updates about the progress of cleanup activity.
           o  Share successes when important cleanup milestones are achieved.
           o  Inform the community about changes in activity that could affect
              reuse plans.

    •   Implement, document and monitor the performance of the cleanup using the
       accepted assessment metrics.

    •   Work with the state VCP, if applicable, and county or local officials to facilitate
       the placement and implementation of institutional controls.
                                           Consider These Questions
                                         Goals and Planning
                                         » How will the cleanup be
                                           monitored and assessed?
                                         » Will long-term monitoring
                                           be required?
                                         » Have alternative land use
                                           strategies been developed?


                                         Oversight
                                         » Are there federal, state, local
                                           and tribal  requirements for
                                           the design, installation and
                                           monitoring of cleanup
                                           activities?


                                         The Community
                                         » How will the community
                                           participate in this phase?
                                         » Are there examples of
                                           effective community
                                           engagement?


                                         Site Specifics
                                         » Can redevelopment and
                                           cleanup activities be
                                           performed concurrently?
                                         » Will ICs facilitate or hinder
                                           redevelopment?  In the
                                           future?


                                         Options
                                         » How will the cleanup design
                                           affect long-term liabilities or
                                           future use of the site?
                                         » What can be done to protect
                                           the community and other
                                           property during cleanup?


                                         Funding
                                         » What a re the tradeoffs
                                           between cost and meeting
                                           project deadlines?
                                         » How will long-term
                                           monitoring be funded and
                                           managed?
38
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Brownfields Road Map
          Design and Implement the Cleanup
                            Find Helpful Resources
                                      Visit the Brownfields Road Map website to identify and review resources
                                      and tools that provide details about technology applications, methods and
                                      other site-specific concerns.
                            Plan Your Next Steps

                            After the cleanup is completed, consider the following courses of action:
                             Result of Cleanup
                             Contamination has been adequately
                             removed, contained or controlled.
                             Additional contamination has been
                             discovered.
                             Long-term site monitoring and
                             operation and maintenance (O&M) of
                             the site remedy is required.
Course of Action
Consult with the appropriate regulatory
officials before you proceed with
redevelopment activities.
Consult with appropriate regulatory
officials to determine how to proceed
with cleanup activities. You may need to
return to the Investigate a Site phase to
conduct additional sampling to delineate
the extent and nature of the
contamination and assess the impact of
additional characterization and cleanup
costs on the overall viability of the project.
Return to the Investigate a Site phase to
evaluate options, including cost
considerations, for long-term monitoring
and O&M, and as necessary collect after-
performance samples for monitoring
cleanup.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
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Design and Implement the Cleanup
                                                   Brownfields Road Map
  Cleanup actions, while protective of the environment, also have their own
  "environmental footprint"—they use energy, water and materials. To reduce this
  footprint, cleanups can be performed in a "greener" manner by considering the
  environmental effects of remedy implementation and incorporating options to
  minimize the impact of cleanup actions. Principles of greener cleanup can be applied
  throughout the site cleanup process, although it can be advantageous to consider
  these options early to reduce the overall footprint of the project. The manner in which
  these technologies or approaches are implemented can produce greener cleanups.
  Greener cleanup BMPs can reduce environmental impacts while maintaining cleanup
  objectives and ensuring that the remedy is protective of human health and the
  environment.
                                                      Materials
                                                      & Waste   I  Ener9V \

                                                              r    ^
                                                              Core
                                                            Elements
                                                    Land&
                                                  Ecosystems
                             Air
                                                              Water
Core Elements of Greener Cleanups
  •  Reduce total energy use by improving energy
     efficiency and increasing use of energy from
     renewable resources.
  •  Reduce air emissions of greenhouse gases and
     criteria pollutants such as ozone, nitrogen
     dioxide and sulfur dioxide.
  •  Protect water resources and reduce water use.
  •  Reduce waste and improve materials management.
  •  Safeguard the land and ecosystem during site cleanup.
Examples of Greener Cleanup BMPs to Consider for Brownfields Projects
  •  Buy local equipment and materials to minimize transportation costs.
  •  Use energy-efficient machinery or vehicles that use alternative energy.
  •  Provide an on-site collection and storage area for compostable materials for use
     on site or by the local community.
  •  Use uncontaminated wastewater or treated water for tasks such as wash water,
     irrigation, dust control and other uses.
  •  Consider renewable energy generation source development as a land reuse
     option.
  •  Reuse salvaged building materials in  redevelopment construction.
  •  Explore production of energy on site to operate remedial systems.
  •  Perform a renewable energy assessment to identify how renewable resources
     could provide future energy needs.
  •  Incorporate low impact development (LID) techniques that view stormwater as a
     resource rather than a waste source.
Examples of Sites Implementing Greener Cleanups
  •  Nitrate-contaminated groundwater at the Apache Powder site in Arizona was
     treated by recirculating it through a gravity-driven, constructed wetland system
     using a pump powered by solar energy.
  •  At the Grove Landfill site in Texas, salvaged site materials such as concrete and
     wood were reused on site for erosion control, mulch and fill, and a tractor
     powered by vegetable oil was used to remove on-site debris.
Government Support of Greener
Cleanups
The U.S. government encourages the
consideration of environmental
footprint reduction at many levels
ranging from Presidential Executive
Orders to Agency policies. Through
The Principles for Greener Cleanups,
issued by EPA's OSWER, the EPA
advances efforts to perform site
investigation and cleanup in a
manner that reduces the
environmental footprint while
maintaining primary cleanup
objectives. In addition, each of the
EPA's 10 regional offices has its own
"clean and green" policy encouraging
the integration  of green remediation
practices into the cleanup process
within their states and territories.

                                                                              Footprint Assessment Tools
                                                                              A variety of tools, such as software
                                                                              models and calculators, are available
                                                                              to evaluate the environmental
                                                                              footprint of remediation processes.
                                                                              The Green Remediation Focus
                                                                              Footprint Assessment website
                                                                              (www.cluin.org/qreenremediation/
                                                                              subtab b3.cfm) provides a summary
                                                                              of available tools, which includes the
                                                                              greener cleanup core elements
                                                                              addressed by the tool, the form in
                                                                              which the tool is available (web-
                                                                              based, decision software or decision
                                                                              matrix) and provides a link to
                                                                              additional information.
                                                                              For More Information
                                                                              The Green Remediation Focus section
                                                                              of the EPA's CLU-IN website at
                                                                              www.cluin.org/qreenremediation
                                                                              provides information on integrating
                                                                              green remediation into cleanups and
                                                                              case studies that describe green
                                                                              remediation implementation.

        Resources for this spotlight are available at www.brownfieldstsc.org/roadmap/spotlight gc.cfm.
40
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Brownfields Road Map
                                                      Appendices
                                  www.brownfieldstsc.org/roadmap
 Brownfields and Technical Support Contacts
  ,
 Acronyms
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 Glossary
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Appendix A - Guide to Contaminants and Technologies

The guide contains detailed information about the types of contaminants
typically found at brownfields sites and the range of technologies that
may be appropriate for assessing and remediating them. The guide will
help stakeholders answer the following questions:
•   Which contaminants are associated with brownfields sites?
•   What technologies may be used to investigate contamination?
•   What technologies may be used to treat contamination?

Information about site types, investigation technologies and treatment
technologies is cross-referenced by contaminant group. Stakeholders can
look up details about 7 general contaminant groups and more than 30
types of brownfields sites, explore technology options for investigating
contamination and review many treatment technologies.

Appendix B - Brownfields and Technical Support Contacts

The Brownfields and Technical Support Contacts page includes links to up-
to-date information for individuals at state, tribal and EPA national and
regional levels who are available to assist cleanup and redevelopment
efforts at brownfields sites. The individuals are a valuable resource for
brownfields stakeholders by providing support and guidance on
applicable laws, regulations and policies and technical assistance
associated with the selection of technologies.

Appendix C - Acronyms and Glossary of Key Terms

A list of acronyms and a detailed glossary of specialized terms used in
discussing and describing brownfields cleanup efforts is available on the
Brownfields Road Map website.
Visit www.brownfieldstsc.org/roadmap for the complete Brownfields Road Map
                                                             A-1

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